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Financial Services Data Management System


A small financial services company in Leeds engaged my services in January 2017 to improve their financial record-keeping, processes and compliance. Registered with the FCA and HMRC, they provide money transmitting services (hawala) to businesses and individuals in the UK and Middle East. This type of business is usually quite informal, and is consequently vulnerable to fraud, money-laundering, litigation, rapid exchange rate fluctuations, adverse publicity and loss of key personnel.

The project objectives were to improve FCA compliance, improve anti-money laundering (AML), improve data quality and reduce business risks in the areas of data protection, business continuity and money laundering.

The project was completed over seven weeks, and involved:
  • Modelling the business data, systems and manual processes.
  • Developing a good understanding of hawala-type business operations.
  • Developing a good understanding of money-laundering, fraud and other criminal activity relating to this business.
  • Understanding the customers of my client and their needs.
  • Produce business descriptions and models to assist accountants, tax inspectors and other authorities (see image below).
  • Risk assessment of data, processes and systems for business, technical, financial and criminal risks.
  • Analysing data for accuracy, currency, definition, integrity and normalisation.
  • Cleaning the data, using multiple data sources.
  • Consolidating data for systems and business intelligence purposes.
  • Making technical, process and business recommendations to improve:
    • Data integrity and accuracy.
    • Transaction traceability.
    • Know-the-customer.
    • Identification of high-risk transactions.
    • The flagging high-risk customers.
    • Data quality and depth available to operators in real-time.
    • Reporting for the business and for customers.
    • Marketing opportunities presented by the data; including:
      • improved market segmentation,
      • direct marketing and advertising,
      • new product development.
    • Policies for data protection, data management and high-risk.
    • Robustness of data processes, such as new customer registration.
    • Backup, data security and physical access controls and processes.
    • Staff training and awareness of legislation, regulations and risks.

  • Improving and building reports, including:
    • Support for benchmarking, monitoring and control of data quality.
    • Risk analysis reports to monitor compliance and internal activities.
    • Data exports for direct marketing, business intelligence and competitive analysis.
    • Template correspondence for customers.

  • Constructing ETL tools in Excel and MS-Access for ongoing data cleansing.
  • Building a management application to replace high-risk spreadsheet systems (see below).
  • Porting (ETL) of all historic data into the new system.
  • Documenting the tools, processes and policies.

The eX Management System built in the course of this project was developed to replace numerous manual and Excel-based data systems. It drives data quality through validation, and drives compliance through encoded business rules. The system was designed as a two-tier, multi-user, proof-of-concept system. It was coded in MS Access at the client's request, for reasons of cost, time-to-completion, iterative development lifecycle, future maintainability and ownership. Many system attributes like colour, form position, alert levels and editing are parameterised, so the client can adjust individual workstations to the user's needs.

Process models; to document the business, inform external parties, and agree system functionality.
Desktop; with basic menu and dashboard.
Customer form; on the 'contact information' tab. This provides employees with a summary of customer activity and raises compliance alerts.
Customer form; on the 'other info' tab. Third parties may be beneficiaries (whom the client sends money to) or payers (who send money to the client), and may be located anywhere in the world.
Customer form; on the 'documents' tab. Electronic copies of all customer documents are stored in a folder hierarchy, improving accessibility, archiving and records management.
Customer form; on the 'transactions' tab. This provides a list of each client's transactions, inward and outward, with the exchange rate and third parties. The 'letter' button at the bottom produces a transaction letter (shown below).
Transactions form; providing a sorted list of all transactions and functionality for basic searches and filters.
Expenses form; used to enter the firm's miscellaneous expenses/income into a basic cashbook. This is used to build a bank reconciliation, profit reports and an Excel export to the accountant for VAT and annual accounts.
Data tools; that allow administrators with permissions to edit lookup tables and master data tables.
Systems tools; to access various functionality. Parameters control add-edit-delete access, colours, permissions, export, folder locations, sort orders, debug mode and other look-and-feel.
Customer information report; used to respond to client FOI requests and HMRC orders.
Customer statement; all transactions and transactions in a date range, provided to a client on request.
Transaction letter; confirming details of a transaction, and provided to a client on request.
Geographical information; Using Google Maps to build a client map, used to focus advertising, marketing and loyalty schemes.