ARTIFICIAL INTELLIGENCE GIVES NEW MEANING TO THE REGULATORY REQUIREMENT OF "KNOWABLE"

Remember when The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA) introduced the term "knowable" to the compliance world, and World-Check came out with its Iran database in response?

Here's a quote from my November 21, 2018 article entitled ' America's Return to Iran Sanctions again raises the Bar for Compliance Officers.'

" CISADA imposes an increased responsibility upon Compliance officers regarding their obligation to access public information on their assigned individuals and entities, above and beyond what has been regarded a best practices, to the 'knowable' level. If significant or relevant information is freely available in the public domain, there is an expectation that such information is knowable, and therefore it must be obtained. This raises the bar significantly for frontline compliance staff,as they are now responsible for information that 'should have been known,' " quoting the US Treasury website.

Assuming, arguendo, that systems employing advanced artificial intelligence, now open the door to a vast open-source of obscure, esoteric, but previously unobtainable goldmine of information, is that data now knowable and therefore there is an expectation that it must be obtained? I believe that the answer must be an unqualified Yes, which means that compliance officers, to discharge their best practices obligations, have no choice but to adopt AI with ML as an integral part of their risk-based compliance program.

Please, put your budgetary excuses from management aside, and add AI-powered programs to your toolbox, lest some smart regulator finds that your compliance program is not only ineffective, it utterly fails to meet minimum standards.