Compliance officers can no longer get away with the old "check-the-box" customer due diligence queries at Account Opening. That level of due diligence has been made obsolete with the adoption of Artificial Intelligence-equipped systems running Machine Learning and advanced analytics. The new resources available through AI are light-years above the old systems, and to properly utilize that data, one must switch to EDD to properly exploit it. Regard EDD now as the minimum standard under banking best practices.
It is high time for compliance departments to create new protocols as minimum standards of inquiry; this means pulling out the EDD playbook, modifying it as needed, and discarding the old DD-level worksheets. Remember, with EDD you must perform a follow-up inquiry on each and every unusual piece of information or data that your AI program locates, which could constitute a Red Flag, and which must be ruled out as a disqualifying high-risk, to avoid a decision to decline the client at Account Opening.
Additionally, and as we have previously explained, due to the fact that your AI-powered queries with produce results that track back to advanced or obscure money laundering typologies, you must also thoroughly train your staff in money laundering Tradecraft, so that they can immediately recognize the indicia of advanced techniques solely from the data in front on them. to do any less will not fully utilize the information that your systems are now producing for your review and analysis.
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