AML Monitoring and Data Processing Platform
Building and Operating a Scalable Compliance Platform for Deutsche Bank & Commerzbank
Context and Regulatory Framework
The platform was designed to meet rapidly evolving regulatory expectations for an effective AFC/AML control framework -- encompassing production-grade transaction monitoring, robust CDD/KYC processes, fully traceable audit trails, and documented internal safeguards.
Risk-Based Monitoring
Transaction monitoring that combines machine learning with rule-based scenarios to maximize detection accuracy.
Data Quality and Validation
Data quality and model validation serve as the foundation for effective controls, backed by fully automated quality assurance processes.
Complete Documentation
End-to-end documentation of all requirements, thresholds, parameterizations, and change history to ensure full audit readiness.
The mandate was clear: deploy a new AML transaction monitoring system (NICE Actimize) while simultaneously building a scalable big data infrastructure capable of meeting these requirements with sustained, high-performance throughput.
Project Deliverables and Implementation
Requirements Management and DRS Creation
We developed and maintained a Data Requirements Sheet (DRS) as the single source of truth for functional, regulatory, and technical requirements. This consolidated KYC/CDD requirements, TM scenarios and thresholds, data quality KPIs, audit trail specifications, and visualization and drill-down capabilities.
Big Data Architecture and Cloud Optimization
We built a high-performance data pipeline on GCP (BigQuery, Hadoop, SparkSQL, BigSQL), processing over 70 million transactions daily with 13 + 3 months of history -- all within a 6-hour window.
Data Quality Management (DQM)
Automated quality assurance covering data completeness, integrity, and referential checks alongside specialized processing routines. Monitoring and alerting via native Google Cloud tooling. On-demand special exports to bridge infrastructure gaps when needed.
Operations, Support, and Enablement
Day-to-day operation of the data pipeline with ongoing performance tuning. Hands-on support for analytics teams and Actimize rule parameterization to drive down false positives. Cloud technology training for internal staff to ensure long-term self-sufficiency.
Technologies and Methods
Big Data and Cloud
GCP BigQuery, Google Cloud Storage (AVRO, JSON), SparkSQL, BigSQL, and Hadoop for high-performance data processing at petabyte scale.
Databases and SQL
PL/SQL, T-SQL, Oracle, and MS SQL Server for complex data integration and transformation across heterogeneous systems.
Compliance and Monitoring
NICE Actimize SAM and STAR combined with AML/CDD/KYC rule frameworks for comprehensive anti-money laundering coverage and regulatory compliance.
BI and Tooling
Looker, Aqua Data Studio, SQL Developer, Jira, and HPQC for visualization, development, and project management.
Challenges and Solutions
Challenge
Processing 70M transactions per day within a tight load window
SIMO Solution
BigQuery performance tuning, parallel load processes, and an optimized bucket strategy using AVRO/JSON
Challenge
Divergent stakeholder requirements across teams
SIMO Solution
Centralized DRS, structured prioritization, and prototype dashboards for early alignment
Challenge
High false-positive rates in AML monitoring
SIMO Solution
Targeted Actimize rule parameterization and ML-driven optimizations
Challenge
Significant training gaps within the client organization
SIMO Solution
Structured workshop series and hands-on on-the-job training
Customer Feedback
We do not disclose client names for data protection and confidentiality reasons. At SIMO GmbH, earning and preserving our clients trust is a core principle.
SIMO GmbH transformed our AML transaction monitoring. The new system cut our false-positive rate by 78% and dramatically improved the efficiency of our compliance department. What stood out most was the seamless migration of 50 million historical transaction records without a single data point lost.
Exceptional technical expertise and professionalism. The deep learning algorithms that SIMO developed for money laundering detection significantly outperform our previous systems. Real-time monitoring of 2.3 million daily transactions has run flawlessly since go-live. This has been an outstanding collaboration.
The regulatory compliance expertise at SIMO is second to none. The new Transaction Monitoring System meets all current BaFin requirements and is built to accommodate upcoming EU regulations. An implementation timeline of just 6 weeks was remarkable.
The custom-built AML solution deserves the highest praise. Intelligent pattern recognition identifies suspicious transaction flows with 94.7% precision. The quality of our FIU reports improved by 60%. SIMO exceeded our expectations across the board.
Results and Impact
SIMO GmbH proved its strength across business, analytics, data integration, and compliance disciplines. By combining deep technical expertise, regulatory domain knowledge, and agile delivery methods, we built a future-proof AML platform that meets the most demanding regulatory standards.
SIMO Team Roles
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