The Age of Digital National AML Risk Assessments Has Arrived

GAB welcomes this post by John Chevis, a former member of the Australian Federal Police, former accountant, and current member of the Intelligent Systems for State and Societal Resilience Hub at the University of New South Wales. As John explains below, he and colleagues at South Wales have developed an AI tool for producing National Anti-Money Laundering Risk Assessments. They are looking for those interested either in using it to conduct an NRA or supporting its further development. John and team can be reached at  j.chevis@unsw.edu.au or johnchevis1@gmail.com

Using Artificial Intelligence to comply with the Financial Action Task Force’s directive to conduct a National Risk Assessment – an exercise to “identify, assess, and understand the money laundering and terrorist financing risks” member states face – would seem obvious.

Financial Intelligence Units collect thousands, in larger countries millions, of reports banks and financial institutions submit about possible money laundering by customers. But a database of what is variously termed Suspicious Transaction or Suspicious Matter or Suspicious Activity Reports is by no means the only source for determining the money laundering risks a nation is exposed to. Other databases with millions of potentially useful records include those on cash transactions, company ownership, land titles, court cases, police investigations, and Politically Exposed Persons. There are also media accounts and social media posts. All grist for an NRA mill.

That’s where AI in the form of Large Language Models comes in. An LLM can sort through massive, unstructured datasets to identify patterns, trends, and anomalies, extracting relationships that human analysts with the most advanced mathematic tools might take years to spot — if ever. When brought to bear on data available to an FIU, the resulting analysis will not only highlight vulnerabilities in the nation’s anti-money laundering regime but provide investigative leads for law enforcement. Precisely the objectives of a National Risk Assessment.

Despite the obvious value of turning an LLM loose on FIU data, our team at the University of New South Wales is, to our knowledge, the first to apply AI to producing an effective digital National Risk Assessment. Funded by the Australian Department of Foreign Affairs and built for the Papua New Guinea financial intelligence unit, it is called “Neon.” Here is how it works. 

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Transcript and Summary of Webinar on Challenges Facing the OECD Antibribery Convention

GAB’s trusty intern (NotebookLLM) finally got around to transcribing and summarizing the January webinar where three former chairs of the group charged with enforcing the OECD Antibribery Convention expressed grave concerns about it continued effectiveness.

Promotional image for a webinar titled 'Challenges Facing the OECD Anti-Bribery Convention.' Features four speakers: Martin Wolf, Drago Kos, Mark Pieth, and Danielle Goudriaan, with text overlay and a purple background.

Moderated by Financial Time’s Chief Economics Commentator Martin Wolf, the speakers highlighted several recent, disturbing developments: the U.S. retreat from vigorous enforcement of the Foreign Corrupt Practices Act, the weak anticorruption directives the European Commission has issued, and political interference in high-profile bribery cases in Italy. 

At the same time, the three — Mark Pieth, now Professor of Criminal Law, Criminal Procedure and Criminology at the University of Basel; Drago Kos, currently Interim Dean of the International Anti-Corruption Academy; and Danielle Goudriaan, presently partner at a leading Dutch law firm —  offered several paths forward.

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