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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Curbing Corruption in Development Projects: Memo for the World Bank Board of Governors

The wAnnual meetingsorld’s finance ministers serve as the governors of the World Bank and meet this weekend to review the Bank’s activities over the last year and set policy for the coming one.  The annual meeting is the first since the OECD released a remarkable document, one that subtly but unmistakably  damns the development community for failing to curb corruption in the projects it finances. In skillfully-crafted prose that points the finger at no one miscreant while charging all with dereliction of duty, the OECD’s Council for Development identifies weaknesses large and small in the corruption prevention efforts of both bilateral and multilateral development organizations and urges major reforms.  Corruption in development projects not only defeats the reason development aid is provided but, as the council stresses, many times leaves the recipient worse off than had no aid been extended in the first place.

The Bank’s Board of Governors should make the report and its recommendations the focus of their meeting. For two reasons. Continue reading

Corruption Risk Assessments: Some Observations on Private Sector Analyses

As the pressure to curb corruption has grown, so too has the demand for “corruption risk assessments,” efforts to predict what form corruption in a public agency or private firm is likely to take and what can be done to reduce if not to eliminate it.  In the private sector risk assessments have been fueled by national laws that reduce penalties for corruption violations if a firm has a risk management program in place.  In the public sector risk assessments help assure citizens that their money is not being stolen and provide an agency leader unlucky enough to be at the helm when a corruption scandal breaks at least a partial defense to charges of incompetence or venality.

Public sector assessments come in several varieties: those which examine the risks faced by a single organization, say the Albanian tax agency, others which assess risks in a publicly-funded program, for example a de-forestation project in the Democratic Republic of the Congo, and still others which consider overall risk in a sector with a large public presence such as water or education.  While public sector assessments are almost always readily available, private sector assessments are not, presumably for proprietary or competitive reasons.  What is available on private sector risk assessment are hundreds (thousands?) of tomes advising firms on how to conduct a risk assessment — often written by those looking to assess the corruption risks a corporation faces for a fee.

A Google search for “corruption risk assessment” produced 300,000 hits, one for “assessing corruption risks” 48 million!  I won’t pretend to have read even a representative sample of the reports or “how to” manuals, but the many I have read so far have been a disappointment. Continue reading