This document proposes an interbank blockchain platform to help banks better detect money laundering and counter terrorism financing. The platform would allow banks to share non-sensitive transaction data in real time. A backend rule engine and later analytics platform would use this pooled interbank data to form risk scenarios, detect complicated placement and structuring techniques, and reduce false positives and compliance costs compared to individual bank systems. Simple example scenarios show how the shared ledger and analytics could help identify suspicious loan repayments or transfers below individual bank detection thresholds that together may indicate placement efforts.

1. 1
THE PROBLEM STATEMENT 3
THE IDEA 3
BENEFITS 3
SIMPLE EXAMPLE SCENARIOS 3
SCENARIO 1 3
SCENARIO 2 4
BASIC ARCHITECTURE 4

2. 2
CONCEPT PAPER
BY UJWAL TAMMINEDI
PURPOSE – Seeking Partnerships and Investments for building and conducting POC with Banks
for the idea articulated and illustrated in this concept paper
UNDERTAKING – This is to my best of knowledge an original idea and work for which I have
used my prior knowledge and secondary research as only tools
UT, 14th November 2016, NICE
UNDERTAKING FOR CONSUMERS – The Idea and contents will be only disclosed and used for
purposes stated above and with prior information to author

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THE PROBLEM STATEMENT
Today AML (Anti Money Laundering) and CTF (Counter-Terrorism Financing) systems are usually
maintained by each bank separately resulting in difficulty in tracking AML placement and
structuring. This usually results, as recent history has shown, in high legal and compliance costs
for banks.
THE IDEA
1. An interbank blockchain platform where “non privacy sensitive” and “non competition
sensitive” transactions will be replicated on real time basis from the transaction systems
of the banks.
2. Having a backend business rule engine (BRE) initially and later a complete analytics
platform to:-
a. To use data from multiple banks for scenario formation and rules in the BRE for
better discovery and risk alerts
b. To use analytics platform to check for detection of various complicated
placement and structuring techniques which are difficult to detect under current
fuzzy logic systemcapabilities
BENEFITS
1. An Inter Bank Public Ledger for easy verification by any bank
2. Blockchain provides immutability
3. With virtual addresses of blockchain we maintain secrecy of customers and at the same
time do not divulge competitive data
4. BRE can have interbank amount, velocity and frequency scenarios for risk identification
5. A common BRE reduces false positives and branch level effort for individual banks
6. Analytics platform can be used to include data analysis for any kind on placement or
structuring schemes
7. This can be looked in a very similar way to credit bureaus case which are used to reduce
systemic risk for financial systemas a whole
SIMPLE EXAMPLE SCENARIOS
Scenario 1
SAMPLE LOAN RULES
TO DETECT
PLACEMENT
Early Termination
Multiple Payments
Third Party Payments Blockchain platform
can reduce false
positives

4. 4
Scenario 2
Assume multiple transfers from different accounts below detection threshold of EUR 3000 as
part of structuring or placement. The blockchain platform can detect the placement based on
originating or destination virtual addresses. This would not be possible unless the velocity and
frequency checks in individual banks detect the same under existing AML systems.
BASIC ARCHITECTURE