WILL BANK SHAREHOLDERS NOW SUE COMPLIANCE OFFICERS WHEN DEPRIVED OF DIVIDENDS DUE TO MASSIVE REGULATORY PENALTIES?

Remember the Law of Unintended Consequences? Whether it will be applied to the AI-powered future of AML/CFT compliance is worth discussing. The vastly expanded treasure trove of information and data potentially available to the compliance officer is a blessing, but with it comes what I see as increased responsibility. If compliance officers now have access to previously-unobtainable information, then they are charged with the proper use of same. This means you had best analyze it, and produce results. This means you stop money laundering and financial crime in your bank, cold.

If I am a wealthy shareholder at an international bank, I have paid a pretty penny for my stock, and like all high net-worth individuals, I fully expect a decent return on my investment. If the bank sustains a multi-million dollar civil penalty for AML or CFT failure, it will impact whether I will be receiving a dividend this year, or even next. The increased resources now available to compliance through the AI revolution means that I am now expecting results, not fines, penalties and agreements with prosecutors that end up costing me my dividend payment. You see, I have come to expect more from my bank's compliance department, now that their staff has AI to help them do their jobs better, and my lawyers agree that there is personal liability verging on compliance malpractice, meaning professional negligence, for failure to ferret out financial crime in the Age of Artificial intelligence. Enter litigation against compliance officers, individually, I fear.

If you think that's bad, it gets worse. Will American prosecutors also get on that increased compliance duty to catch the laundrymen, and indict for willful neglect?

As I see it, the only way out of this dilemma is to equip compliance officers with the knowledge to succeed, which candidly, I am not observing anywhere yet. Unless and until the banking community takes the time to actually teach their compliance staff the tradecraft of money laundering, that new data will neither be understood nor acted upon. The world's banks has consistently failed to educate their staff in most advanced and esoteric money laundering techniques, and until they do so, expect one or more the nightmares listed above to come true. Govern yourselves accordingly, ladies and gentlemen.