We have previously received the feedback that the Elucidate FinCrime Index (EFI) scores are highly concentrated and not helping our clients to precisely discern financial crime risk. Therefore we have taken a few actions to optimise the outcomes. These actions are packaged into release 3 and include:
1. A better way to highlight risks in your anti financial crime governance program. This is done by changing our analysis of the Wolfsberg DDQ. For now on, we are only identifying anomalies in the DDQ in our EFI score calculation so that you can better understand where to focus your remediation efforts.
2. A decrease in weights for static data sources and corresponding increase in weights to dynamic data sources in the data completeness calculation. When calculating data completeness, the Wolfsberg DDQ will count for only a maximum of 10% of the total percentage, with the rest being devoted to institutional data. This is because we believe that dynamic data (i.e. transactions, customers, employees) gives an overall stronger view of your financial crime risk than the answers on the questionnaire.
3. Our impact scores will have a data-driven component to them instead of only being expert assigned.
The EFI model has been recalibrated to bring more authentic and meaningful results to our clients and to enable better decision making.
As a result the scores are more accurate and varied, therefore variable. The industry median as well as scores of our clients have been adjusted accordingly.
As required by the BaFin and ESMA Benchmark Regulation (BMR) to which the EFI is subject, Elucidate's Model Oversight Committee has been informed of the release of the EFI Model version 3.