Our Approach

The Sybase approach is straightforward—using our knowledge and capabilities developed over almost 20 years of managing information, application, and process integration, we rapidly satisfy the requirements of the Act by implementing an automated process for continuous monitoring that is an operationally unobtrusive, secure and cost effective solution. The Sybase PATRIOTcompliance solution was designed to satisfy regulatory requirements by:

• Automating access and updates to the OFAC SDN, FinCEN, and other lists of suspected terrorists and those engaged in illicit activities,
• Automating screening of transactions against suspect lists, as the transactions occur,
• Screening of the Customer Information Files (CIFs—both umbrella and applicationspecific) and company employees against suspect lists,
• Screening of new accounts as they are opened and when they are updated,
• Re-screening of CIFs (and company employee files) as updates to suspect lists are received on an individual basis or screening for all,
• Automating the investigation process through to clearing a suspect by adding them to the excluded list or SAR reporting with historical documentation of the investigation process,
• Automating user notification of suspected matches via email, pager, wireless, or other methods,
• Facilitating electronic interactions with FinCEN, other regulators, enforcement agencies, and financial institutions,
• Facilitating the implementation and maintenance of internal lists for tracking the activity of customers based on specific requirements of an institution,]
• Facilitating the implementation and maintenance of a “cleared” list of account holders that may have been reported as suspects, but through investigation are determined to be legitimate customers,
• Automating support of the “120-hour” investigation requirement,
• Maintaining the historical proof of compliance with the act, and
• Providing an intuitive, secure user environment increasing the speed and quality of searches, while reducing the manual effort and cost associated with satisfying the requirements of the Act.

Our approach recognizes that investments have been made to date for detecting illicit activity. By understanding this, Sybase will work with you to determine how to capitalize on these current capabilities through integrating and extending them as part of the solution. We are able to accomplish this in a cost effective manner through the following:

• Prior identification and analysis of the data elements needed to satisfy the requirements, as they exist in your environment.
• Using pre-built processes, such as automation of OFAC SDN updates, SAR Reports, and reporting formats.
• Having pre-built many of the capabilities necessary to access the data elements from mainframes and a variety of other structured and unstructured information sources
• Implementing a pre-designed schema for the history and investigation management databases, allowing you and Sybase to focus on automating the sourcing of your data that is necessary to satisfy automation of the solution.

For institutions that need to comply with the USA PATRIOT Act, Sybase offers solution components that include: