ACAMS Today Magazine (September-November 2017) Vol. 16 No. 4 | Page 77

AML POLICY Given the magnitude of financial crime and the consequences of not getting ahead of it, regulated financial institutions (FIs) and others within the anti-financial crime com- munity (such as government agencies and affiliates committed to financial crime detection and prevention) need to consider more disruptive and collaborative anti- money laundering and sanctions-related (collectively AML 4 ) strategies. This includes actively exploring and understanding the possibilities associated with openly sharing resources and moving beyond a siloed approach to fuel more advanced, bolder technology-based AML tactics. One route is to pursue the creation of a cen- trally-managed artificial intelligence (AI) tool that can be shared across and devel- oped by multiple institutions in a controlled manner with an independent organization (such as a self-regulatory organization or a government agency) facilitating, governing and overseeing the process. This may be achieved by leveraging and combining three existing strategies: collaboration, centralization and investment in advanced technology. A closer look at these three strategies and the potential applications of AI as it relates to AML, demonstrates why the anti-finan- cial crime community may be ready for the next level in developing and using technol- ogy-based solutions in a collective, open source fashion. Leveraging three existing risk management strategies To get the upper hand in the fight against crime while demonstrating strong business practices and smart investment decisions, FIs need to be better and faster at employ- ing technology to assist with job functions. Fortunately, there are three current tech- niques (collaboration, centralization and investment in advanced technology) that if used together in a new way may facilitate the development and use of AML-related technology within FIs. The following is a brief depiction of each of these areas as they relate to AML. Collaboration As demonstrated in legislation, govern- ment advisories and industry forums, AML advocates recognize that they have an important tool at their disposal: the “power of many.” Sections 314(a) and (b) of the USA PATRIOT Act are commonly referenced when demon- strating the importance of collaboration among the anti-financial crime community. Section 314(a) codifies the provisions relat- ing to information sharing between law Our national security depends on our ability to share the right information, with the right people, at the right time enforcement and FIs. The Office of the Pro- gram Manager for the Information Sharing Environment, noted that “Law enforcement information sharing has expanded signifi- cantly…improving law enforcement’s abil- ity to detect, prevent, and respond to acts of terrorism.... A fundamental component of effective enterprise-wide information shar- ing, for example, is the use of information systems that regularly capture relevant data and make it broadly available to autho- rized users in a timely and secure manner.… Criminal history records, law enforcement incident reports, records of judicial actions and decisions, and watchlists of known and suspected terrorists are all essential sources of vital data that provide accurate, timely, and complete information…” 5 Section 314(b), as FinCEN describes, “provides [FIs] with the ability to share information with one another, under a safe harbor that offers protections from liability, in order to better identify and report potential money launder- ing or terrorist activitie