Sunday, February 12, 2023

ARTIFICIAL INTELLIGENCE GIVES ENHANCED DUE DILIGENCE A SHOT IN THE ARM


Many years ago, I was engaged by a consultancy to perform enhanced due diligence upon a certain individual from Turkey, who was interested in obtaining an economic citizenship in an undisclosed jurisdiction. The objective, of course, was to determine whether the target had anything in his background which might disqualify him for the passport, or worse, place the consultancy in any sort of danger, legal or otherwise.

EDD, using traditional sources and methods, is very labor-intensive, and even after accessing the literally dozens of programs and databases available to you, reaching out to your valued sources abroad, and calling in favors from former law enforcement or intelligence contacts, it is rarely conclusive in totally ruling out your target as a possible financial criminal, if he is from a high-risk region. You usually have a number of unresolved issues, and have to make a judgment call that does leave some stones unturned.

In the case I mentioned, the individual had some unconfirmed, vague association with significant transfers of gold, but I could never get confirmation of that particularly bothersome rumor, no matter how many sources I accessed. I ruefully gave the target a clean bill of health, with a caveat about one issue that I was unable to resolve to my satisfaction, plus my nagging suspicion about his name change.

You know where this is going, of course; fast forward several years, and my target surfaces as a major player in international sanctions evasion, arrested, in a classic way, upon arriving in Miami with his family, en route to Disney World. His final destination ended up being a pretrial jail in New York for Federal prisoners.

If I had been using a platform, such as is available today, featuring artificial intelligence, I would have gotten the confirmation that I needed to identify the target as a transnational sanctions evader for Iran, because my searches would have reached the remote and arcane data sources that, when assembled into a pattern as they were found, using the machine learning capability, would have turned my distant rumor into documented fact. AI can give EDD the teeth it needs to retrieve the answers that have eluded it in the past.

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