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