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6 Considerations for Your AML Transformation Programme

Insights from the session ‘The Evolving Role of Financial Crime Compliance’ at Napier’s Disrupt Fincrime event in London, by Mark Gregory, Director Forensics Practice, PwC UK.

Mark Gregory
July 4, 2023

Financial crime compliance (FCC) plays a vital role in protecting the integrity of the financial system and ensuring institutions safeguard themselves against regulatory repercussions. As the financial landscape evolves, so too do the demands on compliance professionals.  

The Current Landscape of Financial Crime Compliance

Financial institutions face significant challenges in establishing and maintaining an effective control environment that is agile and responsive to evolving regulatory expectations and the threat landscape. The landscape of FCC is shaped by various factors, including continued regulatory focus and change, increasing awareness and complexity of risk, effectiveness and impact of compliance efforts, high cost of compliance, poor industry alignment, and changing business and customer expectations.

To overcome these challenges, financial institutions must adopt a holistic and risk-based approach to compliance. Compliance professionals must navigate a complex web of regulations, interpret, and implement evolving guidelines, and strike a balance between compliance requirements and operational efficiency. Additionally, compliance efforts need to be effective, impactful, and address the root causes of financial crime.

Here are the 6 key considerations for fincrime professionals designing their digital transformation programmes.  

1. Alignment: Focus on preventative controls

The industry is shifting towards preventative controls over detective controls. Financial institutions are implementing real-time monitoring and risk-sensitive products and services. Furthermore, controls are being integrated into digital business channels to ensure compliance is embedded seamlessly into customer interactions.

Learn from fincrime executives who are designing Next Gen AML that balances innovation and regulation.

2. Collaboration: Share intelligence sharing and best practices

Financial institutions are leveraging public-private partnerships to share intelligence. These collaborations enable the exchange of valuable insights, best practices, and emerging threat information. Additionally, innovation sandboxes and alliances with RegTech firms, like Napier, allow for experimentation and the development of cutting-edge compliance solutions.

Discover how the regulator and industry can collaborate on synthetic data for financial crime compliance.

3. Convergence: Adopt a holistic risk management approach

There is an increasing recognition of the need to consider risk holistically across various domains. Financial institutions are now aligning Know Your Customer (KYC) processes with ongoing monitoring, ensuring a comprehensive view of customer behaviour, with concepts like Perpetual Client Risk Assessment (pCRA) gaining traction amongst forward-thinking institutions.

Creating a holistic view of financial crime risk: download this guide to learn how financial institutions can easily gain a dynamic view of risk.

4. Data Analytics: Leverage insights for effective compliance

Quantifying risks and control effectiveness linked to risk appetite is crucial in enhancing compliance practices. Custom business and product risk-sensitive models and solutions are being developed to address specific risks. Furthermore, feedback loops and model validation play a significant role in ensuring the accuracy and efficiency of compliance controls.

How to build a resilient Client Screening programme: design your controls and data analytics.

5. Intelligence: Enhance data quality and coverage

Financial institutions are increasingly relying on external data sets to improve data quality and coverage. This enables a more comprehensive understanding of customer behaviour and helps identify potential risks. As data privacy becomes a priority, institutions are adopting privacy-preserving techniques to protect sensitive information. Link analysis and entity resolution are employed to enrich and validate data, ensuring a holistic view of compliance-related information.

Diving into the right data, at the right time: Read Insights from Gem Conn, Vice President, Content Strategy & Quality, Dow Jones Risk & Compliance, on empowering compliance through the right data strategy.

6. Automation and Artificial Intelligence (AI): Streamline compliance processes.

Robotic process automation is being used to automate basic investigation tasks, freeing up compliance professionals to focus on more complex activities where human intervention is needed the most. Machine learning is leveraged in detection models, including unsupervised and semi-supervised approaches, to enhance the accuracy and efficiency of identifying potential financial crime. Additionally, graph analytics is employed to support models and investigations, enabling a deeper understanding of interconnected patterns and relationships.

But regulatory provision for AI applications in decision-making are very nascent due to the need for explainability and clear audit trails, so true artificial intelligence should focus on creating automated recommendations for human review. The decision and the accountability still sits for fincrime professionals.  

Learn more about global regulatory approaches to AI for AML in this ebook.

Vision for the Future

The landscape of Financial Crime Compliance is evolving rapidly, posing challenges for financial institutions, and opportunities for fincrime professionals to truly innovate. By embracing the innovation opportunity and adopting this framework, FCC teams can strengthen their compliance frameworks, enhance risk mitigation capabilities, and ensure a secure and trusted financial ecosystem.

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 Effective management of financial crime threats will be increasingly underpinned by a technology-enabled and continuous assessment and scoring of risks with each customer interaction and event.​ A continuous, timely, and comprehensive understanding of clients and counterparties across previously siloed risks areas will become table stakes.  

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