INEFFICIENT AML PROGRAM CAUSED U.S. REGULATORS TO DENY TD BANK THE ACQUISITION OF FIRST HORIZON BANK

For those banks that continue to cut corners, and thereby costs, from their AML/CFT compliance programs, I direct you to this week's sad story; TD Bank whose planned acquisition of First Horizon Bank was abruptly terminated after government regulators has made the determination that TD's program was inefficient, and therefore represented an unacceptable level of risk.

I will be repeatedly, and regularly, using America's financial institutions to supplement their new Artificial Intelligence-power systems with adequate training of their frontline staff in money laundering tradecraft, for all this new data will be wasted upon untrained compliance officers who cannot recognize advanced techniques in the new batches of data that AML programs will be cranking out for their review.

To be blunt, your junior compliance officers have never studied, let alone seen, the esoteric and obscure techniques, and unless they can spot them from the data flowing past each day, the benefits of AI will not only be lost upon them, you will suffer the fare of TD, or worse, when the fact that the answers were knowable to your staff, based upon the data made available to them, but they failed to identify and interdict the money laundering, solely through ignorance of the techniques employed.