THE ESSENTIAL OF DATA AND ROLE OF

DATA DRIVEN SUPERVISORS TO SUPPORT

SUPTECH EFFECTIVENESS
Bank Indonesia Flagship Seminar Morning Session
New Era for Consumer Protection: Panel 1
Use of Digital Innovation Session 2

June 9, 2022
AGENDA

Background: AMF & FinTechs, dataflow, and technologies

Strategy for building reliable structure

Leveraging data to support our supervision

Key takeaways

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 BACKGROUND: AMF & FINTECHS,
DATAFLOW, AND TECHNOLOGIES

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S FINTECHS

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S FINTECHS – HUBS AND SPOKE

Data governance and valuable usage of

data are done within the business lines.

The hub is a facilitator.

The node is a connector to the
business line.

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S DATAFLOW – DIAGRAM

Data Analyst

Non-structured and test data is

archived in the Sandbox

Reporting entity
sends a structured
disclosure form using
secured on-line
service (SEL) or an
automated disclosure
transfer service Sandbox
(STAD)

The disclosure form

content is automatically
validated using criteria Data consumer
defined by risk experts
Enterprise Our risk experts use
Data Warehouse structured and non-
structured data to
(EDEN) perform analysis and
oversight of various risks
Analysis Tools
The validated
structured data is
Risk
All of our dashboards,
archived in the data Datamart analytical alerts, tables and
warehouse (EDEN). graphs are created from
Our risk data mart is a
subset of the data various data marts
warehouse oriented to
a specific business line
or team.

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S DATAFLOW – DATA COLLECTION

Disclosure forms compliant

with financial disclosure laws
sent by deposit-taking Data collected from internal
institutions : classified systems : Information center,
confidential information, Adhoc Data requests
structured or may be
unstructured.

Data collected from external

systems by AMF analysts :
unstructured data, APIs

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S DATAFLOW – DATA WAREHOUSES

Enterprise Data Warehouse (EDEN) Sandbox

• Structured data from disclosure • Unstructured data originating from
forms external systems
• Unstructured data (stable through • Flat files
time) • Historical data
• Data validation rules • Ad-hoc data
• Data experiments

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S DATAFLOW – DATAMARTS

• Top-Down structure : starting from Data Warehouses to develop and

construct the Data marts
• Answer to business needs : Data Marts are organized by risk type and/or by
deposit-taking institution
• Modelling : Data marts are built based on the star scheme
• Granularity : Scope of Data Marts will expand gradually due to cyclicality
• Information sharing : Data Marts are shared through Share Point to
encourage cross-sectoral collaboration

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S DATAFLOW – VISUALISATION

• Drill down the different semantic layers of data

• Slicing and dicing info by sorting and filtering
• Manipulating prebuilt report / scheduled report including alerts for monitoring
• In accordance with the needs of senior management
• Power BI on premise server : for confidentiality reasons reports are not
shared on the cloud

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BACKGROUND: AMF & FINTECHS, DATAFLOW, AND TECHNOLOGIES
AMF’S TECHNOLOGIES

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 STRATEGY FOR BUILDING
RELIABLE STRUCTURE

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STRATEGY FOR BUILDING RELIABLE STRUCTURE
WHY IS A STRATEGY ESSENTIAL?
SupTech Strategy
4,8%

• To align efforts with the institution’s

strategic objectives
33,3%

61,9% • To mitigate implementation

obstacles such as :
– Structural issues : resources and skills
needed, supervisory culture
Authority has a SupTech strategy in place – Data-related problems : quality, availability
Authority is considering the implementation of a SupTech strategy
No formal strategy in place
SupTech Tools for Market Conduct Supervisors, November 2020, FincCoNet.
21 respondents.

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STRATEGY FOR BUILDING RELIABLE STRUCTURE
A CLEAR SUPTECH STRATEGY
Benefits AMF’s Experience

• Gaining in maturity for SupTech and • The SupTech strategy is articulated

RegTech in general around 3 pillars:
• Having a better understanding of – Proactivity
– Proximity
what we need
– Agility
• Building a solid in-house expertise
• A formal process is essential to
and using it for future projects
determine needs, identifying most
valuable projects and prioritizing
them

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STRATEGY FOR BUILDING RELIABLE STRUCTURE
AMF’S STRATEGY – SUPTECH TOOL DESIGN

Identification • Stakeholders must collectively identify and share needs

of needs • Centralizing the requirements to allocate resources efficiently

Prioritization • Filtering out unrealistic, inefficient or excessively costly

initiatives
of initiatives • Better to start small than too big

Mobilization • Allocating appropriate resources such as time and expertise

of resources • Monitoring the project to ensure that objectives are met

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 LEVERAGING DATA
TO SUPPORT OUR SUPERVISION
• Offsite Supervision
• Analysis of a Large Volume of Qualitative Data
• Misleading Information – SEDAR

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
CHALLENGES RELATED TO DATA
Quality Availability
Large amounts of data are not
Disclosure requirements are
necessarily available when
sometimes interpreted differently by
implementing SupTech tools, such as
financial institutions.
for machine learning.

Standardization Representativeness
Efforts are made to make information To allow the use mathematical tools in
consumable, especially for SupTechs, adequate sampling is
unstructured data. required.

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
OFF-SITE SUPERVISION CASE

The solution
The objective The challenge
Implement a system to
Develop risk profiles and Large volume of data with various
gain time and
early warning indicators. analysis reports.
standardize the outputs.

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
OFF-SITE SUPERVISION CASE
Data Analyst

Non-structured and test data is

archived in the Sandbox

Reporting entity
sends a structured
disclosure form using
secured on-line
service (SEL) or an
automated disclosure
transfer service Sandbox
(STAD)

The disclosure form

content is automatically
validated using criteria Data consumer
defined by risk experts
Enterprise Our risk experts use
Data Warehouse structured and non-
structured data to
(EDEN) perform analysis and
oversight of various risks
Analysis Tools
The validated
structured data is
Risk
All of our dashboards,
archived in the data Datamart analytical alerts, tables and
warehouse (EDEN). graphs are created from
Our risk data mart is a
subset of the data various data marts
warehouse oriented to
a specific business line
or team.

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
OFF-SITE SUPERVISION CASE – LEASONS LEARNED

• Dashbords ease interactions with upper management by ensuring

productivity and effective communication of strategic messages
• Automation really leads to efficiency : the information is available sooner and
quality is consistent
• Experimentation is a key factor for success
• Development can be time consuming

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
ANALYSIS OF A LARGE VOLUME OF QUALITATIVE DATA CASE

• Definition of basic topic modeling : evaluate a text’s subject

• Instead of reading the files/data one by one to evaluate the subject, we use a
topic modeling technique
• More efficient to process high volumes of data
• Topic modeling and NLP are the main technologies used

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
ANALYSIS OF A LARGE VOLUME OF QUALITATIVE DATA CASE

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
AMF’S COMPLAINTS CASE
Evolution of subject trends over time

Subject X16
ssq
assurer
résilier
risquer
auto
nouveau
résiliation
aviser

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
MISLEADING INFORMATION CASE (SEDAR)

The objective The challenge

The solution
Identify potential Time-consuming manual analysis of
Include AI to automatize
misleading information financial information submitted and press
the process.
for investors. releases.

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LEVERAGING DATA TO SUPPORT OUR SUPERVISION
MISLEADING INFORMATION CASE – LESSONS LEARNED

• Machine learning requires a lot of knowledge of the data

• Rule-based NLP algorithms may be better for generalization than machine
learning
– Ease transparency of results
– Rules can be created on concepts for which some related items may not be present in the data set
• Open source frameworks are really efficient
• Solutions requires iterative development processes with inputs from analysts

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 KEY
TAKEAWAYS

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KEY TAKEAWAYS
HOW SUPERVISORS CAN SUPPORT SUPTECH EFFECTIVENESS?

By supporting collaboration and sharing initiatives

– Capitalize on others’ experimentation, failures and successes
– Every initiative to develop Suptech tools shall be seen as a continuous learning process

By sharing work approaches and best practices

– Common goals should be the main motivation, such as supervisory mission, consumer
protection or financial stability
– Common standards

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 QUESTIONS

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 ANNEX

How Technology Can Help?

ODDI: A Dynamic Insider Trading Detection Tool

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HOW TECHNOLOGY CAN HELP?
ODDI: A DYNAMIC INSIDER TRADING DETECTION TOOL
ODDI : Improving Detection and Investigation of Insider Trading Cases Through Network
Analysis

Key objectives:
• Consolidate available databases
• Identify persons of interest on social networks
• Use Business intelligence to asses big volumes of data
• Use deep learning or other AI techniques to extract relevant information
• Automatize the process to:
– Identify family, business or control links
– Deduce networks of people possibly linked together
– Regroup identical persons extracted from different sources

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HOW TECHNOLOGY CAN HELP?
ODDI: DATA SOURCES AND WORKFLOW

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HOW TECHNOLOGY CAN HELP?
ODDI: EXAMPLES OF LINKS IDENTIFIED

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HOW TECHNOLOGY CAN HELP?
ODDI: EXAMPLES OF LINKS IDENTIFIED

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HOW TECHNOLOGY CAN HELP?
ODDI: RESULTS
• ODDI helps investigators:
– re-create the chronological timeline of events leading to the actual trading,
– combining amounts of data from various sources (orders & phone records, amongst others) to help
bring out the circumstantial evidence necessary to enable the use of more traditional investigation
techniques such as search & seizures.
• So not only ODDI helps us better detect cases, it helps the investigators to analyse data
more quickly and effectively.
• ODDI started as a project 3 years ago and is now used in every single Insider trading case.
• It played a central role in the detection & investigation in AMF’s most recent major cases,
including the Beauchamp Case, the Bronze Case and the Larivière Case.
• ODDI has already helped the AMF enforce several illegal insider trading cases over the last
3 years.

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