On 11 March 2025, FinTechTalk host Charles Orton-Jones was joined by Robert L. Williams III, Anti-Money Laundering Consultant.
What does a good AML department look like?
A good AML department starts with people on the one hand, and you must have the right policies and procedures in place too, where the strong link between the two is provided by employees buy-in when it comes to compliance.
Plugging in the right system is not enough, you need to use your AML database and AML alerts effectively too. AI is already being used in AML but hasn’t reached its full potential yet and it’s not taking away the job of AML investigators just yet but is tremendous help with cutting down the number of false positives.
What type of AI is used in AML?
Financial institutions can have their internally built systems, or they can put their data base in an external system in line with their customer base, geography and risk appetite. There is a huge difference between what rule-based and adaptive AI-driven models can do.
ML may struggle with AML due to the small data available of criminals who have been caught, as well as quickly changing fraud patterns. Also, criminals often opt for crypto when laundering money because of the ease with which it can be done there and tools that can help them cover their tracks such as crypto mixers.
Although the rationale behind the current US legislation is that money in a US-based institution is less risky than the money in a foreign one, it is not necessarily true. However, governments could do more given that the money spent globally on AML efforts at 2-5% is the same as it was about two decades ago.
AML systems with capabilities such as IP address tracing can be much more effective than ones without those features, while small community banks with limited resources can’t afford to buy advanced AML systems and therefore should probably get government support in order to be able to implement them. There is room for improvement in how governments are fighting against money laundering too.
In the UK, for example, the Companies House register includes a bank allegedly run by a shop in North London which is registered to have billions of dollars in assets.
There are certifications that AML experts can obtain such as CCAS (Certified Cryptoasset Anti-Financial Crime Specialist) or ACFCS, which offers participation at its annual week-long summit for the membership fee.
Trump coin issued by the US president, which foreign governments can buy into without being subjected to any SEC scrutiny, is seen by experts as state-style looting.
The panellists’ insights
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