COMPLIANCE OFFICERS, USE AI TO REVISIT YOUR HIGH-RISK CLIENTS, BEFORE LAW ENFORCEMENT DOES

If I was a director of compliance at a major international bank today, I would detail my staff to employ advanced artificial intelligence platforms to revisit my prior due diligence investigation of all current high-risk and high-value bank clients. I do that because AI/ML programs will uncover information and data that was previously unknown to me, but which law enforcement agencies and regulators, using AI, might find first, and target my bank for ineffective compliance, or worse, and levy civil or even criminal penalties.

Remember, other parties can also find incriminating information about your bank clients; you had best find it first. While it may sound like an expensive proposition to review all your high-risk clients, think about the consequences if the FBI or the DEA, using AI, find out that your esteemed bank client is a drug kingpin, and that fact shows up today in an investigative article about his arrest and seizure of accounts at your bank.

AI is therefore to be considered mandatory for this purpose, if you are truly operating a risk-based compliance program. To do otherwise exposes your bank to an unacceptable level of risk. Do not forget that if information is knowable, meaning that technology exists capable of finding that information, the failure of compliance to access and possess that data, is by definition ineffective, and we know what happens when this is the conclusion of law enforcement and/or regulatory agencies. Find the data before some agency does, please,