Sunday, April 2, 2023

THE USE OF ARTIFICIAL INTELLIGENCE TO IDENTIFY DOMESTIC TERRORISTS AT ACCOUNT OPENING AND IN YOUR CLIENT BASE

As a compliance officer seeking to be the gatekeeper against terrorist financiers, when the individuals are domestic terrorists, the task has historically been so difficult as to be impossible to implement. Unless your new client is arrested, or has a criminal record, you won't find him anywhere when conducting due diligence. Only a tiny percentage of domestic terrorist organizations are on any sanctions list; new ones pop up constantly, and traditional news coverage is often months behind their quiet birth. Forget using any commercial-off-the-shelf database of high-risk persons or entities, as they do not focus on including incidents that may later be classified as domestic terrorism. Their domestic nature excludes them from OFAC or any government list, unless they are wanted by law enforcement. On the other hand, FinCEN has identified domestic terrorist financing as a priority for US banks.

So, how does a compliance officer at a major American financial institution determine if John Smith is possibly a domestic terrorist engaged in low-level terrorist financing, or providing material support to a terrorist organization? Will you only find out when a serious terrorist operation occurs, with you literally trying to explain to your superiors how your bank's name just showed up in the media as the place where he or she put money together to finance a bombing of government office? As you know, one can fund a terrorist act without raising a substantial sum; Financial activity linked to domestic terrorism can be extremely hard to identify in advance.

The answer is to deploy a platform using Artificial Intelligence, featuring Machine learning, to reach deep into your customer's life, to a degree that even enhanced due diligence cannot penetrate. Obscure local newspaper articles, covering arrest reports, incidents that may or may not be precursor actions caused by a newly-appeared organization, such as protest events, violent encounters with minorities , all of which you have never been able to find, can now be accessed, using AI.

If your bank has branches located in traditionally rural, politically Red states, your threat level is elevated for domestic terrorists as current clients, and at account opening. You are advised to discuss this with outside counsel competent to reach out to local and Federal law enforcement to ascertain your level of risk. If it is significant, the expense of have your compliance department review customer files is justified, versus the possible negative media exposure of your bank bening named as a place where domestic terrorists were able to assemble sufficient funds to commit a fatal act in the United States.

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