Detailed rationale for every hit

Raworths is a Harrogate based law firm of around 70 people. We spoke with Jamie Metcalf, who is the Risk and Compliance Manager and the firm's money laundering reporting officer (MLRO), and leads the firm’s approach to client due diligence. 

Private client work makes up much of what the firm does, including many high net worth clients across Harrogate and North Yorkshire, and its residential conveyancing team handles most of  the highest-risk matters. 

Alongside screening, the firm uses Thirdfort for identity verification and occasional Source of funds reviews.

Jamie deals with many anti-money laundering screening hits. That can be time-consuming and hard to stay on top of. With Thirdfort's Screening Agent reading each hit and writing up its reasoning, he clears the obvious false positives in moments and keeps his attention for the hits that matter.

So many “John Smiths”

Screening a client against politically exposed person and sanctions lists throws up matches by name alone, and for a firm like Raworths many of them are false positives. Each one still needs a decision, and each decision needs a written reason that would stand up to scrutiny or audit. As MLRO, that routine work competed with everything else on his desk, from training to day to day compliance queries.

About the time it takes to review hits, Jamie told us, “The vast majority of screening hits are false positives. Looking at them and dismissing them one by one takes up a lot of time, and you have to write up the reason every single time.”

There was a second worry too. Jamie wanted to be able to prove that a match had been considered, not just assume it had.

“Unless something is written down, you can't prove that you've thought about it.”

An early adopter, with humans firmly in charge

Raworths was one of the first firms to test the Screening Agent, and Jamie's feedback has helped shape it. The agent reads each screening hit, compares it with what the firm already knows about the client, such as their date of birth and where they live, and recommends whether to dismiss it or escalate it. It writes the reasoning down so that Jamie can either agree with it in a click, or take a more detailed look if needed.

Jamie adopted it in stages. He started by checking every recommendation himself, then took the case to the firm's board, and once the recommendations kept matching his own judgement, he allowed the screening agent to do its job. The agent now dismisses only the matches it is confident about. Any hits where the agent believes it is a positive match, or is unsure of, still comes straight to him, and the agent sends back a regular sample of its automatic dismissals so he can check its work and show that oversight is happening.

He still manually reviews every potential politically exposed person hit with particular care, even when the agent is sure it is a false positive, adding his own notes to the agent’s draft notes where he has compared a client's likeness with publicly available images of the politically exposed person.

What changed for Raworths

Since the Screening Agent started making recommendations, Jamie has agreed with every dismissal it has proposed: 243 out of 243, with only the occasional additional note to give further clout to what the agent has already summarised. Since turning on automatic dismissals, the agent has assessed 331 screening matches for Raworths and settled 135 clear false positives  without anyone needing to look, while the rest came to Jamie with the suggested reasoning already written. By his own account the agent also cut the time he needs to spend on reviews by around 90%.

According to Jamie the agent has been really effective, “It's been great at being efficient about dismissing the really obvious false positives, whilst continuing to escalate the ones that need my review, either because it’s not totally sure or it believes the hit relates to the client.”

Oversight across the whole process

The Screening Agent sits inside Thirdfort, which Jamie says has changed how much he can see.

He makes a habit of looking back over the previous day's completed checks, sees at a glance which matches have been reviewed and which have not, and leaves a note when he has reviewed one so there is a record that someone looked. 

Want to see the Screening Agent on your own screening hits? We're ready when you are.