By Frank Cummings, CEO of AML Partners
What is Directed Intelligence for AML Compliance?
As the traction for AI in AML accelerates, institutions have decisions to make. What tools? What training methods? What safeguards? Here at AML Partners, we are working to make AI in AML/CTF more transparent and more specific to each institution’s distinct needs. To achieve that, we are pioneering Directed Intelligence.
Directed Intelligence refers to the capturing—as digital data—of every decision made by Compliance and GRC professionals in an organization. RegTechONE, our AML software platform, makes possible Directed Intelligence for financial institutions and other organizations.
Directed Intelligence data provides an extraordinary digital archive of Compliance pre-decisions and operations that are stored within RegTechONE. With Directed Intelligence, institutions digitally archive every decision made by their own Compliance and GRC experts. With comprehensive Directed Intelligence data, institutions can then train their AI tools to align precisely with their AML program.
Directed Intelligence on the RegTechONE platform solves the problem of out-of-the-box AI, the training of which is an opaque ‘black box’ to financial institutions. Directed Intelligence is the crucial bridge to AI tools that can be trained in-house.
Why is black-box AI a problem in AML Compliance?
AML Compliance requires organizations to create Risk-based approaches unique to their needs. Organizations need to be able to explain their Risk-based approach and every element of its implementation to examiners and auditors. With AI trained in-house using Directed Intelligence, an organization can explain precisely how its AI tools were trained.
With out-of-the-box AI tools, organizations get an AI ‘trained’ on data, decisions, and actions that originate outside of the organization. Without leveraging Directed Intelligence data, the vast majority of organizations have no choice but to trust these opaquely trained AI tools or else avoid their use.
Institutions that choose Directed Intelligence on the RegTechONE platform solve the problem of opaque AI. Directed Intelligence as a transitional bridge between legacy systems (i.e. systems pre-AI) and AI represents an extraordinary opportunity. Institutions will be able to adopt AI—and still adhere fully and transparently to their unique Risk-based Approach.
Your Directed Intelligence is the best teacher of your AI
The institution that uses AI is the best teacher of that AI. There is no better ‘curriculum’ with which to train your AI than your own Directed Intelligence–your pre-decisions, your workflows, your Key Risk Indicators, your everything.
Training your AI in-house with your Directed Intelligence data leverages the expert work over time of your compliance officers, analysts, auditors, operations personnel, and front office. In AML Compliance and related high-stakes GRC, training your AI to your own specifications gives you crucial transparency and control. That transparency and control are unavailable to you with an out-of-the-box AI tool.
How do institutions get started with Directed Intelligence in AML?
Directed Intelligence—your bridge to in-house-trained AI—requires use of RegTechONE, the RegTech software platform designed by AML Partners. RegTechONE provides the ideal AI training data because it is a no-code workflow-creation platform. And RegTechONE also archives every action, every change, and every decision executed by your AML software. Simply by using RegTechONE for your AML software solution, you are archiving your institution’s planning, decision-making, and operations for AML Compliance.
Why RegTechONE is the key to AI trained in-house
We designed RegTechONE, our GRC and AML software platform, to provide ‘Your Work, Your Way’ configurability. And we designed it to integrate end-to-end AML Compliance modules and your preferred AML tools from other vendors. We also designed it to ‘Comply on the Fly’—end-users edit and update workflows and other configurations at will. RegTechONE requires no coding—only configuration by your own Compliance professionals. Your own AML Compliance experts operationalize in RegTechONE their best thinking on behalf of your institution and its Risk-based Approach. All of this effort and AML expertise is captured and archived in RegTechONE’s Directed Intelligence data.
RegTechONE in normal use by your institution captures every pre-decision and every operational decision. With this data, we can train your AI in the ways your institution executes its unique Compliance program. Our ‘Your Work, Your Way’ mission means RegTechONE provides the perfect bridge to an in-house-trained AI. RegTechONE makes possible Directed Intelligence—a comprehensive data capture perfect for training your AI to do your work, your way.
How RegTechONE mirrors your AML Compliance program
RegTechONE archives an exceptionally rich dataset of Directed Intelligence that includes comprehensive details of an institution’s AML Compliance programming and decision-making. Examples include the following:
- Pre-decision making—Your Compliance Officer defines a set of pre-decisions that are then configured into dynamic workflows in RegTechONE. These dynamic workflows align precisely to your unique Risk-based Approach. These workflows represent factors like your unique Risk appetite and your book of business. These details provide a crucial foundation for training your AI, and RegTechONE archives them all as Directed Intelligence.
- Operational decisions—RegTechONE features Event and Action Libraries configured by Compliance Officers to monitor for specific events or behaviors and then execute actions configured by the Compliance officer. For example, a pre-defined suspicious behavior might trigger the action of automatically emailing Compliance personnel or automatically creating a case. Not only does RegTechONE archive all the configurations, but it also preserves all the events and actions that occur. And it preserves any edits to the configurations and any actions taken by authorized end-users. All of this becomes part of your institution’s Directed Intelligence.
- Your Work, Your Way—We designed RegTechONE to achieve ‘Your Work, Your Way’ no-code configurability. This means that RegTechONE mirrors the choices and decision-making of your own in-house Compliance experts. And RegTechONE provides a comprehensive digital record–i.e. Directed Intelligence–of every workflow, every edit, every event, every action, every decision.
Achieve In-house trained AI step by step at your pace
Because RegTechONE’s Directed Intelligence provides the bridge between legacy software solutions and full artificial intelligence, institutions can choose their own pace and strategic approach. RegTechONE users can convert the platform to artificial intelligence one step at a time. With verified valid training data available on RegTechONE, all four major functions of AML—KYC CDD, sanctions screening, behavior and transaction monitoring, and FinCEN 314/subpoena search—can be trained in stages. Institutions using RegTechONE for daily GRC and AML Compliance work are automatically creating the Directed Intelligence to train AI tools.
To learn more about how we can help you move toward AI trained in-house, contact us today.
