Monday, January 2, 2023

ARTIFICIAL INTELLIGENCE CAN SUPPLY CRITICAL INFORMATION NEEDED FOR EFFECTIVE ENHANCED DUE DILIGENCE INVESTIGATIONS

Readers who have heard me lecture about my decade as a money launderer know that I subsequently used those experiences when working as a compliance officer using enhanced due diligence techniques to investigate high-risk foreign nationals who sought to make multi-million dollar investments with a company located in the United States.

The tools I employed included the legacy systems currently used by the vast majority of compliance officers, but I found that, in many cases, they were insufficient, and at times even ineffective, in problem solving. 

In one case the prospective client was himself a financial services professional, for Uruguay, investing, or so he claimed, for his own account. As you know, Uruguay has a long history as a destination for "flight capital" from countries such as Argentina, much of which constitutes the Proceeds of Crime. Was he acting on behalf of a criminal client? 

I found that there was a singular lack of useful information available regarding my target, using conventional EDD sources and methods, which I deemed unacceptable, forcing me to institute time-consuming manual searches of data sources not included even in what are said to be comprehensive AML resources. Traditional sources had him coming up clean, but I considered them insufficient for this specific case, given that data from his country of origin is minimal.

A tedious trial-and-error search of the archives of world's largest newspapers, querying their files for information that presently does not even exist in today's negative news platforms, turned up an article, for years ago, in a Sydney newspaper, regarding the target's representation of a fugitive Mexican narcotics kingpin. Armed with that piece of intelligence, and based upon my follow-up research, I was able to properly act as gatekeeper and bar the door to the individual. Had I had then possessed access to platforms powered by Artificial Intelligence, I would have located that information in a flash, not several hours later.

AI can make the critical difference between success and failure, resulting in Account Relationship staff onboarding a client, who never should have been accepted. Pairing AI with machine learning and critical analysis is a game-changer for compliance, and one that is widely recognized, the current situation, which clearly fails to timely identify money launderers, will tip back in favor of compliance. Make it happen, people.





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