TO MAKE THE BEST USE OF YOUR AI PLATFORM, COMPLIANCE DIRECTORS MUST EDUCATE FRONTLINE STAFF ON AML TRADECRAFT, OR FACE THE POTENTIAL CONSEQUENCES

You are a compliance director at a major international bank, and have deployed state-of-the-art AML/CFT programs, with advanced artificial intelligence and featuring machine learning, which you know now constitutes banking best practices in your jurisdiction. Have you done all you should do to insure that your frontline compliance staff will catch the money launderers and terrorist financiers who target your bank each day?

Unfortunately, the answer is no, unless you have thoroughly trained your staff ib tradecraft, the specific methods and techniques that laundrymen employ to successfully deceive your staff, and move the proceeds of crime into, and through, your bank. What I have found is a singular absence of training on this critical topic, which I consider an abject failure of whoever is in the leadership position, because to properly utilize AI and ML results, one must be aware of the tricks of the money launderers' trade, namely their specific techniques, or the data your AI program delivers to you will neither be understood, nor acted upon, on a real-time basis. Your people will not be able to interpret the information that the new technology gives them. AI is only as good as the competency of its users.

You will not only need to conduct recurring tradecraft training, you must properly document this training in your records, and then obtain written confirmation from your staff that it has been accomplished, within the scope of your established training program, to protect not only the bank but yourself, ladies and gentlemen. We live in very litigious times, and if I am a major shareholder of your bank, and my annual dividends are not going to be paid for the next couple of years, due to a massive regulatory fine, coupled with a costly expansion of the compliance program, to remedy a failure to detect a major money laundering operation, I will advise my client to bring a civil suit against you for professional negligence. You do not want to be on the wrong end of a large judgment, individually, and end up blacklisted in your chosen profession. The worst case scenario is a criminal prosecution; sound like something you wish to avoid?

Therefore, teach tradecraft regularly to your staff, document this training, and make it an integral part of your compliance program, so they can catch the bad guys in the act, and you won't be waking up in the middle of the night, wondering whether you can financially and professionally survive your staffs' failures.