On April 18, 2023, ACAMS New York Chapter hosted an in person event titled Optimize your AML Program for Effectiveness, which was sponsored by Sayari. The event was moderated (pictured from left to right below) by Nirvana Patel (Managing Partner, Unicore Growth Partners and Board Member, ACAMS New York Chapter) and included the following panelists: David Lynch (Global Head of Analytical Solutions, Sayari); Pawneet Abramowski (Founder & Principal, PARC Solutions LLC) and Keith Harding (Head, AML Integration and Emerging Trends, Citi).
The discussion began with background on the various phases of legislation that the US Government has gone through –the Bank Secrecy Act phase; the USA PATRIOT Act phase; and now the AML Act phase, which calls for a focus on risk management effectiveness in addition to technical compliance. Program optimization is therefore more important now than it ever has been.
A key theme of the discussion was the importance of using data as a foundation for optimization. This can be implemented by understanding and planning: 1) access (how we can get data into systems); 2) validation/connection (the ability for data sets to talk to each other); and 3) actioning (understanding how we use the data). When developing solutions, financial institutions should always begin with identifying the problem. The appropriate technology can then be found to address that particular problem (the audience was warned not to identify technology as a first step). The panelist stressed the importance of business and compliance stakeholders collaboration, where both can benefit in various ways from the data and optimization efforts to accomplish different objectives.
Graphs can also be extremely valuable in order to identify threat patterns and visually demonstrate where the risks lie. However, data needs to be strong in order for the patterns to be accurately presented. For example, financial institutions should be aware that defensive SAR filing can skew data inappropriately.
Several of the questions from audience members pertained to the incorporation of AI technology. Panelists advised that AI tends to be used on the business side more often than in Compliance at this time. This technology can, however, be very valuable for entity resolution (e.g., making internal and external data connections). Any use of such technology does not eliminate the need for human subject matter experts to train the machine.
The discussion concluded with the following panelist takeaways: structured and clean data is critical, processes using this data must be adaptable. Additionally, an effective AML program will rely on the strength of data integration.