Challenge: Give compliance teams the tools to work more effectively and flexibly on regulatory investigations.
Solution: Build an "ingest and search" data platform based on Hitachi Content Platform to transform compliance operations.
Headquartered in Utrecht, Netherlands, banking and financial services company Rabobank serves more than 10 million customers in 47 countries. Employing over 51,000 people worldwide, Rabobank manages around EUR 674 billion of assets and reported a net profit of EUR 2.1 billion as of December 2015.
Walter Hendriks, Change Manager for Global Compliance at Rabobank’s Financial Economic Crime Unit, explains, "Rabobank, like all financial institutions, is subject to a wide range of strict government regulations in each of the countries in which it operates. With banks facing evermore scrutiny since the 2008 financial crisis, and with new regulations always on the horizon, we wanted to enable a solution that would be rapid, flexible and comprehensive for current and future compliance investigations."
"Previously, IT, on behalf of Rabobank’s Global Compliance Group, gathered communications data from multiple sources in multiple countries," adds Colin Chatelier, Head of Data Center (UK) and Global Storage at Rabobank. "This might include email, recorded voice calls, instant messaging and chat applications, as well as Instant Bloomberg and Eikon Messenger from Thomson Reuters: time-consuming, resource-intensive and error-prone task."
Chatelier continues, "When the compliance division needed to examine a particular set of corporate actions, we collected the data from these diverse sources: some from third-party vendors, and some held on backup tapes. If an enquiry changed scope, we might have to search the same systems with different criteria. We wanted to address the problem of consistently mining multiple data sources spread across many disparate silos, with no obvious way of joining one communication type to another, by helping compliance teams work more flexibly and collaborate more easily.
To search for and retrieve digital assets more efficiently, Rabobank looked to create a solution that would collect every piece of relevant data into a single place. By creating a central, comprehensive data set, Rabobank could complete compliance investigations without the need to return to source systems, even if the scope changed. Further, the data could be correctly managed, with compliant access control, audit trails and automated policy-driven deletion. Secure audited retention at object level replaced the need to throw a retention blanket over the entire data silo.
In a project sponsored by the Global Compliance Group, Rabobank engaged Hitachi Vantara to build a cutting-edge ingest-and-search platform based on Hitachi Content Platform (HCP) technology. This solution was expected to automatically collate, secure and index both structured and unstructured data across the business.
"What initially attracted us to HCP was its unique and exceptional suitability for compliance systems," says Chatelier. "Equally as important was finding the right partner for this project. Previous experience of Hitachi Vantara hardware meant we knew we could rely on Hitachi Vantara to provide a rock-solid solution."
As data is ingested into HCP, it is simultaneously indexed and made searchable. Data is then separated by source, such as email or voice, and by country, so that access and retention policies can be applied according to the requirements of each jurisdiction.
Overlaying this system is an easy-to-use, interactive web interface that enables investigative searches by pre-approved individuals of the compliance teams. The solution allows the Global Compliance Group to define its own queries, and only the right people on the right teams have access to the data sources relevant for their investigations. Additionally, based on a single, comprehensive data store, all potential data sources, such as email, voice, SMS, documents and more, can be screened to ensure proper regulatory compliance.
To ensure solution resilience, two HCP appliances run as an active-active pair, one in the Netherlands and one in the UK; should one site suffer a catastrophe, the other HCP system simply continues uninterrupted. This twinned arrangement acts as a backup and archive for all the local systems, removing a major headache for the IT team. Simultaneously, the high-availability HCP pairing ensures that a comprehensive, consolidated record of bank interations is always accessible for compliance investigations.
With the HCP-based ingest-and-search platform, the Global Compliance Group has simplified access to the data needed for investigations at its fingertips in a single, central portal.
"The HCP solution has significantly improved the efficiency and flexibility of investigations, and cut the time needed for discovery searches from weeks to hours," says Chatelier. "Approved users can get all the data they need from their desks, and simply get on with their jobs, without having to ask for help from IT. The compliance team is able to work more effectively and efficiently, while reducing the workload impact on IT staff."
He adds, "As a result, the IT team is released from administrative data search and retrieval tasks, and can move to proactive business matters. The HCP solution gives us control over the uncontrollable. As an immutable source of data, compliance teams can be safe in the knowledge that information has not been altered in any way. Data held in the HCP solution is complete, comprehensive and auditable, and allows us to both prevent deletion and apply automated, irretrievable erasure according to compliance policies."
Given the success of the project, Rabobank plans on adding further data sources to the platform, including trading applications messaging and Skype for Business.
"With our HCP-based solution, Rabobank is setting a new standard for compliance investigations in the banking sector. We are confident that other institutions will follow in our footsteps," says Chatelier.
"The regulatory landscape is constantly shifting. The HCP solution enables compliance investigations to be completed rapidly and securely, across global business units. Most importantly, HCP gives Rabobank control of its data, with a flexible, comprehensive solution and the ability to meet future compliance needs," Hendriks concludes.