AI IN AML CAN OPEN DOORS PREVIOUSLY CLOSED, WITH USEFUL RESULTS IN LOOKBACKS

 

With the advent of AML platforms using Artificial Intelligence, users are far more likely to find obscure or isolated references to information which was not heretofore available. The challenge is to make sense of that seemingly unrelated data, and linking it to the target of your EDD inquiry. My advice is to cast a broad net when trying to decipher what appears to be an irrelevant piece of information, because AI has found something of interest; your task is to connect it up.

AI-powered systems frequently stumble upon references that you would like to immediately discount; don't do it, seek out the relevance. Perhaps an illustration of how much new data you can now have available to you through AI might be helpful regarding lookbacks.

Regular readers of my blog might remember the late career criminal from Miami's "Golden Age" of cocaine trafficking, RAMON NAVARRO, not to be confused with the silent film star of a similar name. Ramon, known in the Miami drug underworld as "Turko," due to his Middle Eastern ethnic background, was a career criminal who engaged in relieving other drug traffickers of their dope or cash, knowing that they could not complain their losses to the police. A somewhat colorful character, he liked to pack an automatic weapon in his trunk, and a handgun in his sock, when carrying out his activities. He was even known to commit some of these crimes whilst some of his children were actually in the car. 

A decade ago I wrote about this individual, in an article entitled The Perils of Being a Witness in a Money Laundering Case {August 3, 2013}, because Navarro, who was to be an important witness against General Manuel Antonio Noriega in Miami, when he mysteriously died in a one car accident, involving his BMV coupe. it was never solved. At the time, there was precious little information available regarding Turko. I only had intelligence available to me due to my contacts in the Miami Vice world. Compliance officers back then, without the benefits of AI platforms, fared worse should they be seeking information.

Fast forward to the present day; compliance officers who might have a reason to search out information about Turko due to EDD on some other individual, and who are using an AI-enabled resource, would find an obscure case entitled United States vs. William Saldarriaga, 987 F.2d 1526 ( 11th. Cir. 2013), in which he is not a party defendant, but was, prior to his untimely death, a drug trafficker using a cocaine smuggling vessel seized en route by Colombian authorities when traveling northbound. he was a co-conspirator with Saldarriaga, and the decision contain extensive information about Turko. Like a lot of traffickers, he was multitasking smuggling and ripping off his competition at the same time.

There is a strange coincidence in the case.The defendant was represented by the late Steven Kreisberg, a criminal defense attorney in Miami whom I had previously worked with, but at the time of the appeal in 1991, I was a guest of the Bureau of Prisons. Had AI platforms for AML existed at that time, the docket in the Federal court file would have surfaced in the inquiry, and any compliance officer with such access would have had the benefit of a large amount of relevant information to help him make an informed decision about an EDD query. There is a lesson here.

Therefore, note to compliance officers performing required historial lookbacks; you will want to revisit the old queries, using your Artificially Intelligence platforms, because additional information will surface that was not previously available. It might answer some of your questions, or even those of the regulatory agency that is demanding answers from you.