Evaluating AI adoption in AML programs

Deen Favaedi, Phoebe Zhou
| 5/16/2024
A software engineer analyzes code for AI adoption in an AML compliance program, visualized by a futuristic interface with financial data and algorithms

AI adoption carries several potential benefits and challenges. Is it right for your AML program?

Many financial services organizations are turning to artificial intelligence (AI) to bolster their operations and combat financial crime. The increasingly rapid pace of AI adoption underscores an urgent need for organizations to evaluate how they could use AI technology strategically in their anti-money laundering (AML) programs while mitigating risk and meeting compliance requirements.

By understanding how implementing AI technology into AML programs might streamline processes and improve accuracy and by considering the potential benefits, challenges, and use cases, financial services organizations can make better informed decisions about whether to implement it.

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Why AI?

Financial services organizations can use AI technology in their AML programs to align with other AI-based enterprise initiatives and create efficiencies in their processes. Additionally, organizations can use AI to combat fraud and reduce false positive rates, streamline know your customer (KYC) and AML frameworks, and enhance transaction monitoring systems.

Combating fraud and reducing false positive rates. Financial services are implementing AI technology, but bad actors also employ AI toward their own ends. In fact, fraud rates have increased significantly since the emergence of AI technology, and since the COVID-19 pandemic began in 2020, check fraud has increased by 385%. However, organizations that use AI in fraud prevention, specifically in alert or event evaluation, have seen 70% fewer false positives, based on a study by the technology and information services firm CSI.

Streamlining KYC and AML processes. Integrating AI into an organization’s AML program can improve many aspects of business processes, including increasing efficiency and accuracy and assisting in real-time detection. Additionally, AI-based applications that use deep learning and large language models (LLMs) can enhance KYC and AML programs by improving identity verification, as AI technologies can help confirm or reject a new customer’s identity in real time. Strengthening KYC and AML programs is critical in protecting customers and avoiding potential fines. In 2022, $5 billion in fines were levied against financial services organizations for various AML, sanctions, and KYC system failures.

Improving transaction monitoring. AI technology can enhance transaction monitoring for AML compliance. By using advanced analytics and machine learning algorithms, AI-powered systems can identify suspicious patterns and anomalies in real time or near real time. These AI-based transaction monitoring solutions can analyze vast amounts of data from multiple sources, including customer profiles, historical transactions, and other relevant information. The algorithms can detect behaviors that deviate from a user’s past activity or exhibit characteristics indicative of money laundering or terrorist financing. The ability to generate timely alerts for these suspicious activities allows compliance teams to focus their efforts on the most high-risk cases rather than on false positives.

Implementation challenges – and potential benefits

Many smaller financial services organizations are not fully prepared to embrace advancements in AI technology, which might stem from a combination of factors, including a shortage of expertise in AI and the complexity of implementation. According to a study by Amazon, 75% of companies within the banking sector seeking to hire AI specialists are finding it difficult to fill their AI talent requirements. Financial services organizations have a critical need for AI talent as they evaluate AI deployment across the enterprise and within their financial crime programs.

While AI technology implementations require both hard- and soft-dollar costs, the overall savings and benefits can outweigh the time and resources needed. The costs to implement an AI-based model vary by organization size, but for general context, implementing LLMs such as GPT-3 can cost around $50,000 to $100,000 for the GPU hardware alone and around $10 to $24 per hour to run. For a smaller scaled AI implementation, certain AI models can cost around $10,000 to $30,000 for the GPU hardware. The exact cost depends on the specific AI model, hardware requirements, data preparation, integration needs, and scale of the implementation. Some organizations might want to pretrain, or build an LLM from scratch, and those costs can escalate into the millions.

Certainly, incorporating AI technology into an AML program involves cost. But according to a study by Juniper Research, AI can potentially save banks $900 million in operational costs by 2028. By automating processes, financial services organizations can save human resources for more complex tasks and enhance their overall customer experience by mitigating the number of bad actors in the system.

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Specific AML use cases

Some potential ways AI technology can be deployed in a financial crime program include:

KYC onboarding AI models. An AI-based model can automate identity verification for new customers by analyzing documents, historical data, and other metrics. The model can quickly analyze the authenticity of documents provided by the potential customer and identify any discrepancies. This automation can streamline the onboarding process, enhance the customer experience, and reduce the risk of identity fraud while complying with regulatory requirements.

Predictive analysis for risk assessment. When using AI, predictive analysis can assess the risk profiles of customers and transactions based on behavioral patterns, historical data, and counterparties. An AI model can identify patterns and anomalies in transactional data, enabling organizations to identify potential risks associated with the customer. Financial services organizations can more effectively mitigate risks and prioritize resources by predicting the likelihood of suspicious activities.

Suspicious activity report (SAR) narrative generation. An AI-powered process can automate the generation of detailed narratives for suspicious activities identified by the organization’s AML system, improving efficiency in compliance reporting. Using natural language processing algorithms, an AI model can swiftly analyze data including transactional, customer, historical, and previous SARs to generate initial drafts of narratives that provide insights into potentially suspicious activities. Organizations can significantly reduce the time and resources required for compliance reporting by implementing an automated process.

AI graph analytics for network analysis. AI-generated graph analytics can review networks of financial transactions and relationships, uncovering hidden patterns indicative of money laundering and supporting proactive risk management. Using machine learning algorithms to assess transactional data, such models can identify unique clusters of related entities and transactions and help organizations flag potential instances of suspicious activity for further investigation.

Behavioral biometrics. Using AI, behavioral biometrics can authenticate users and detect suspicious activity in real time, enhancing security measures and fraud detection capabilities. AI-trained behavioral biometrics can help financial services organizations reduce the risk of unauthorized access or fraudulent transactions, improve customer experience, and provide insights into customer behavior.

Alert models. AML compliance teams rely heavily on rule-based transaction monitoring systems, which often yield a high rate of false positives that strain resources and hinder investigators’ efficiency. To mitigate this issue, organizations can develop AI models that automatically learn complex patterns from customer, transactional, and historical data. These models focus on the individual alert level, assigning each alert a score ranging from 0 to 1 based on its likelihood of resulting in a SAR. By integrating these predicted probabilities into organizations’ AML systems, organizations can better allocate resources by prioritizing high-probability alerts, reduce false positives, and improve efficiency.

AI adoption for AML programs

The rise of AI presents an opportunity for financial services organizations to fortify their AML systems and improve operational efficiencies. However, developing a greater awareness of the uncertainties and potential regulatory challenges regarding AI adoption is critical. Financial services organizations that are more fully equipped with resources and knowledge about AI are more likely to plan effective AI adoption strategies.

As organizations learn more about AI technology and potentially seek third-party vendors for implementation, understanding the benefits and drawbacks can help control the steps taken to strengthen their AML programs. By adopting AI technology, organizations can enhance efficiency and accuracy, better serve customers, and maintain compliance amid an evolving regulatory landscape.

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