Shifting from Procedure-Driven to Intelligence-Driven Financial Crime Compliance

The traditional procedure-driven approach to Financial Crime Compliance (FCC) and Anti-Money Laundering (AML) is no longer effective in combating financial crime. A new, intelligence-driven, investigator-centered approach is needed to intercept high-risk proscribed activities.

Key Recommendations

1. Invest in Technology

• Implement advanced machine-learning algorithms to process and filter large amounts of data
• Enable investigators to understand institutional exposures to high-risk parties

2. Build a Network of External Partnerships

• Collaborate with local law enforcement, other financial institutions, tax-collection agencies, shipping companies, airlines, social-media companies, and nonprofits
• Share intelligence and improve investigations

3. Realize Activities and Platforms

• Streamline current FCC/AML operations by stopping unnecessary activities
• Automate manual tasks and free up resources for more valuable actions

4. Elevate the Profile of Financial Institutions as Socially Responsible Actors

• Improve detection and reduce financial crime
• Build public confidence in the financial system

Benefits of an Intelligence-Driven Approach

Dramatically Improved Effectiveness

• Increased signal-to-noise ratio, focusing efforts on high-value actions

Reduced Strain on Organizational Resources

• Gains from process improvements could be reinvested in special investigative teams

Elevated Profile as Socially Responsible Actors

• Building public confidence in banks and the financial system

Deeper Regulatory Engagement

• Encouraging banks to share information and create public-private partnerships

By adopting an intelligence-driven approach to FCC/AML, financial institutions can improve their effectiveness, reduce costs, and enhance their reputation.