The Opportunity for Intelligent Process Automation in KYC / AML

Posted on : 28-06-2018 | By : richard.gale | In : compliance, Data, Finance, FinTech, Innovation

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Financial services firms have had a preoccupation with meeting the rules and regulations for fighting Financial Crime for the best part of the past decade. Ever since HSBC received sanction from both UK and US regulators in 2010, many other firms have also been caught short in failing to meet society’s expectations in this space. There have been huge programmes of change and remediation, amounting to 10’s of Billions of any currency you choose, to try to get Anti-Financial Crime (AFC) or Know Your Customer (KYC) / Anti-Money Laundering (AML) policies, risk methodologies, data sources, processes, organisation structures, systems and client populations into shape, at least to be able to meet the expectations of regulators, if not exactly stop financial crime.

The challenge for the industry is that Financial Crime is a massive and complex problem to solve. It is not just the detection and prevention of money laundering, but also needs to cover terrorist financing, bribery & corruption and tax evasion. Therefore, as the Banks, Asset Managers and Insurers have been doing, there is a need to focus upon all elements of the AFC regime, from education to process, and all the other activities in-between. Estimates as to the scale of the problem vary but the consensus is that somewhere between $3-5 trillion is introduced into the financial systems each year.

However, progress is being made. Harmonisation and clarity of industry standards and more consistency has come from the regulators with initiatives such as the 4th EU AML Directive. The appreciation and understanding of the importance of the controls are certainly better understood within Financial Services firms and by their shareholders. Perhaps what has not yet progressed significantly are the processes of performing client due diligence and monitoring of their subsequent activity. Most would argue that this is down to a number of factors, possibly the greatest challenge being the disparate and inconsistent nature of the data required to support these processes. Data needs to be sourced in many formats from country registries, stock exchanges, documents of incorporation, multiple media sources etc… Still today many firms have a predominantly manual process to achieve this, even when much of the data is available in digital form. Many still do not automatically ingest data into their work flows and have poorly defined processes to progress onboarding, or monitoring activities. This is for the regulations as they stand today, in the future this burden will further increase as firms will be expected to take all possible efforts to determine the integrity of their clients i.e. by establishing linkages to bad actors through other data sources such as social media and the dark web not evident in traditional sources such as company registries.

There have been several advances in recent years with technologies that have enormous potential for supporting the AFC cause. Data vendors have made big improvements in providing a broader and higher quality of data. The Aggregation solutions, such as Encompass offer services where the constituents of a corporate ownership structure can be assembled, and sanctions & PEP checks undertaken in seconds, rather than the current norm of multiple hours. This works well where the data is available from a reliable electronic source. However, does not work where there are no, or unreliable sources of digital data, as is the case for Trusts or in many jurisdictions around the world. Here we quickly get back to the world of paper and PDFs’ which still require human horsepower to review and decision.

Getting the information in the first instance can be very time consuming with complex interactions between multiple parties (relationship managers, clients, lawyers, data vendors, compliance teams etc) and multiple communications channels i.e. voice, email and chat in its various forms. We also have the challenge of Adverse Media, where thousands of news stories are generated every day on Corporates and Individuals that are the clients of Financial firms. The news items can be positive or negative but consumes tens of thousands of people to review, eliminate or investigate this mountain of data each day. The same challenges come with transaction monitoring, where individual firms can have thousands of ‘hits’ every day on ‘unusual’ payment patterns or ‘questionable’ beneficiaries. These also require review, repair, discounting or further investigation, the clear majority of which are false positives that can be readily discarded.

What is probably the most interesting opportunity for allowing the industry to see the wood for the trees in this data heavy world, is the maturing of Artificial Intelligence (AI) based, or ‘Intelligent’ solutions. The combination of Natural Language Processing with Machine Learning can help the human find the needles in the haystack or make sense of unstructured data that would ordinarily require much time to read and record. AI on its own is not a solution but combined with process management (workflow) and digitised, multi-channel communications, and even Robotics can achieve significant advances. In summary ‘Intelligent’ processing can address 3 of the main data challenges with the AFC regimes within financial institutions;

  1. Sourcing the right data – Where data is structured and digitally obtainable it can be readily harvested but needs to be integrated into the process flows to be compared, analysed, accepted or rejected as part of a review process. Here AI can be used to perform these comparisons, support analysis and look for patterns of common or disparate Data. Where the data is unstructured i.e. embedded in a paper document (email / PDF / doc etc.) then AI NLP and Machine Learning can be used to extract the relevant data and turn the unstructured into structured form for onward processing
  2. Filtering – with both Transaction Monitoring and Adverse Media reviews there is a tsunami of data and events presented to Compliance and Operations teams for sifting, reviewing, rejecting or further investigation. The use of AI can be extremely effective at performing this sifting and presenting back only relevant results to users. Done correctly this can reduce this burden by 90+% but perhaps more importantly, never miss or overlook a case so providing reassurance that relevant data is being captured
  3. By using Intelligent workflows, processes can be fully automated where simple decision making is supported by AI, thereby removing the need for manual intervention in many tasks being processed. Leaving the human to provide value in the complex end of problem solving

Solutions are now emerging in the industry, such as OPSMATiX, one of the first Intelligent Process Automation (IPA) solutions. Devised by a group of industry business experts as a set of technologies that combine to make sense of data across different communication channels, uses AI to turn the unstructured data into structured, and applies robust workflows to optimally manage the resolution of cases, exceptions and issues. The data vendors, and solution vendors such as Encompass are also embracing AI techniques and technologies to effectively create ‘smart filters’ that can be used to scour through thousands, if not millions of pieces of news and other media to discover, or discount information of interest. This can be achieved in a tiny fraction of the time, and therefore cost, and more importantly with far better accuracy than the human can achieve. The outcome of this will be to liberate the human from the process, and firms can either choose to reduce the costs of their operations or use people more effectively to investigate and analyse those events, information and clients that maybe of genuine cause for concern, rather than deal with the noise.

Only once the process has been made significantly more efficient, and the data brought under control can Financial firms really start to address the insidious business of financial crime. Currently all the effort is still going into meeting the regulations, and not societies actual demand which is to combat this global menace, Intelligent process should unlock this capability

 

Guest Author : David Deane, Managing Partner of FIMATIX and CEO of OPSMATiX. David has had a long and illustrious career within Operations and Technology global leadership with Wholesale Banks and Wealth Managers. Before creating FIMATIX and OPSMATiX, he was recently the Global Head of KYC / AML Operations for a Tier 1 Wholesale Bank.

david.deane@fimatix.com