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Future of Business and Finance

Abhishek Gupta
Dwijendra Nath Dwivedi
Jigar Shah

Artificial
Intelligence
Applications in
Banking and
Financial Services
Anti Money Laundering and Compliance
Future of Business and Finance
The Future of Business and Finance book series features professional works aimed
at defining, analyzing, and charting the future trends in these fields. The focus
is mainly on strategic directions, technological advances, challenges and solu-
tions which may affect the way we do business tomorrow, including the future
of sustainability and governance practices. Mainly written by practitioners, con-
sultants and academic thinkers, the books are intended to spark and inform further
discussions and developments.
Abhishek Gupta ·
Dwijendra Nath Dwivedi · Jigar Shah

Artificial Intelligence
Applications in Banking
and Financial Services
Anti Money Laundering and
Compliance
Abhishek Gupta Dwijendra Nath Dwivedi
Effiya Technologies Private Limited Department of Economics and Finance
Singapore, Singapore Cracow University of Economics
Kraków, Poland
Jigar Shah
Effiya Technologies
Ahmedabad, India

ISSN 2662-2467 ISSN 2662-2475 (electronic)

Future of Business and Finance
ISBN 978-981-99-2570-4 ISBN 978-981-99-2571-1 (eBook)
https://doi.org/10.1007/978-981-99-2571-1

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Goddess of knowledge and our parents
Acknowledgments

Writing a book on this topic was inconceivable for me till a few years ago. I have
been a consultant throughout my career with a bit of flair for teaching and writing
for journals. It was all about crisp communication, and condensing thoughts for
senior management, who have an attention span of not more than five minutes.
Transitioning from there to a detailed book has been a journey. Throughout the
journey, I was inspired by my wife Liudmyla, who kept me motivated, made nice
exhibits, and proofread for me. It was her support that made me finish the book on
time. I would also like to acknowledge my mom and sisters who always motivated
me to achieve higher goals and never settle for mediocrity in life. They have always
been a source of inspiration for me. A special thanks to my team Ashish Jain,
Indrani Biswas, Ravi Saroj, and Jay Modi, who provided all the necessary data-
driven research, proof of concept, and other analyses, that helped me provide a
few practical perspectives in this book. Last but not least, a special thanks to the
Springer team that helped us throughout the process and kept providing guidance
on topics that were new to us as authors.
I, along with my co-authors, would like to acknowledge the contribution of the
following professionals, who have provided their valuable input and insights:
Mr. Jas Anand, Senior Partner Risk, Advisory, Ernst & Young LLP, Canada
Mr. Victor Matafonov, Head of Group Compliance, Emirates NBD, UAE
Mr. Abhishek Jhunjhunwala, Head of FCC Advisory, Tata Consultancy Services,
India
Mr. Nipun Srivastava, Managing Director FCC advisory, Protiviti Middle East
Mr. Dawn Thomas, Director, Governance Risk and Compliance, Crowe UAE
Mr. Amit Keshri, Chief Compliance Officer, Bank of Baroda, UAE
Mr. Kantilal Bhati, Head of Compliance, National Bank of Oman, Oman

Abhishek Gupta
Singapore, Singapore

vii
Contents

1 Overview of Money Laundering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Overview of Various Type of Money Laundering . . . . . . . . . . . . . . 2
1.3 Mechanism for Laundering Money . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1.3.1 Financial Crimes Combatting in the USA . . . . . . . . . . . . . 6
1.3.2 Financial Crimes Regulatory Evolution in the EU . . . . . 7
1.4 Financial Institution’s Response to Combatting Money
Laundering and Terrorist Financing . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
1.5 The Outcome of Increasing Focus on Financial Crimes . . . . . . . . 10
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2 Financial Crimes Management and Control in Financial
Institutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2.1.1 Governance Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2.1.2 Active Monitoring of Financial Crime Events . . . . . . . . . 15
2.2 Organization Design for Financial Crimes . . . . . . . . . . . . . . . . . . . . . 18
2.2.1 Customer Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
2.2.2 Sanctions Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
2.2.3 Financial Transaction Monitoring from an AML
Perspective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
2.2.4 Ongoing Customer Risk Assessment . . . . . . . . . . . . . . . . . . 19
2.2.5 Regulatory Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
2.2.6 Legal Team . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
2.2.7 Cybersecurity Team . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
2.3 Reporting Structure in Financial Organization . . . . . . . . . . . . . . . . . 21
2.4 Performance Management for the Compliance Team . . . . . . . . . . . 22
2.4.1 Efficiency of Monitoring Systems in Place . . . . . . . . . . . . 23
2.4.2 Organization Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
2.4.3 Operational Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
2.4.4 Regulatory and Internal Audit Reviews . . . . . . . . . . . . . . . . 24
3 Overview of Technology Solutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
3.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
3.2 Modules of the Solution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
ix
x Contents

3.2.1 Customer Onboarding Solution—KYC Risk

Scoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
3.2.2 Financial Transaction Monitoring . . . . . . . . . . . . . . . . . . . . . 29
3.2.3 Case Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
3.2.4 Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
3.3 Backend or Technical Functionalities . . . . . . . . . . . . . . . . . . . . . . . . . . 31
3.4 Organizations’ Needs from AML Solutions . . . . . . . . . . . . . . . . . . . . 32
3.5 Market Overview of AML . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
3.6 Emerging Trends in AML Solutions . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
4 Data Organization for an FCC Unit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
4.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
4.1.1 Data Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
4.1.2 Presence of Outliers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
4.1.3 Data History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
4.2 Data Dimensions Relevant for Analysis on Financial
Crimes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
4.3 Cross-Border Data-Related Challenges . . . . . . . . . . . . . . . . . . . . . . . . 49
4.4 GDPR-Related Data Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
4.5 Areas of Improvement for Creating Best-in-Class Data
Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
4.6 Knowledge of AI and Its Enablers for Compliance Heads . . . . . . 53
4.7 Improving Data Quality and Integrity in KYC . . . . . . . . . . . . . . . . . 54
4.8 Desiloing of Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
4.9 Having the Right Lead for Data Organization . . . . . . . . . . . . . . . . . . 54
4.10 Evolution of Best-in-Class Data Organization . . . . . . . . . . . . . . . . . . 55
5 Planning for AI in Financial Crimes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
5.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
5.2 Forces Shaping the FCC Ecosystem . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
5.3 Pitfalls to Avoid When Designing AI-Enabled FCC
Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59
5.4 Setting up Roadmap for AI Organization . . . . . . . . . . . . . . . . . . . . . . 60
5.5 Building Blocks of a Best-in-Class AI-Enabled
Compliance Function . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
6 Applying Machine Learning for Effective Customer Risk
Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
6.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
6.2 Know Your Customer (KYC) Processing . . . . . . . . . . . . . . . . . . . . . . 66
6.2.1 Automated Alerts for Expiry and Renewals . . . . . . . . . . . 67
6.2.2 Automation of Information Extraction . . . . . . . . . . . . . . . . . 67
6.2.3 Computer Vision Application on e-KYC . . . . . . . . . . . . . . 67
6.3 Sanctions and Watchlist Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
6.4 Expectations from Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
6.4.1 Challenges for Name Screening . . . . . . . . . . . . . . . . . . . . . . . 68
Contents xi

6.4.2 Approaches for Name Screening . . . . . . . . . . . . . . . . . . . . . . 69

6.4.3 Impact of Machine Learning Algorithms on Name
Matching . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72
6.4.4 Process for Training Machine Learning
Algorithms for Name Matching . . . . . . . . . . . . . . . . . . . . . . . 72
6.5 Customer Due Diligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74
6.5.1 Onboarding CDD Scorecard . . . . . . . . . . . . . . . . . . . . . . . . . . 76
6.5.2 Machine Learning Models for Customer Due
Diligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
6.5.3 Ongoing Due Diligence and Dynamic Customer
Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
6.5.4 Conversion of Machine Learning Outcomes
into Smart AI Engines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78
7 Artificial Intelligence-Driven Effective Financial Transaction
Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
7.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
7.2 Threshold Finetuning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
7.2.1 Objectives of Threshold Finetuning . . . . . . . . . . . . . . . . . . . 84
7.2.2 Cross-Scenario Optimization . . . . . . . . . . . . . . . . . . . . . . . . . . 89
8 Machine Learning-Driven Alert Optimization . . . . . . . . . . . . . . . . . . . . . . 93
8.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93
8.2 Various Approaches for Assessing Customer Riskiness
Through Machine Learning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94
8.3 Customer-Level Monitoring and Scoring . . . . . . . . . . . . . . . . . . . . . . 95
9 Applying Artificial Intelligence on Investigation . . . . . . . . . . . . . . . . . . . . 105
9.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105
9.2 Information Needs for an Investigator . . . . . . . . . . . . . . . . . . . . . . . . . 106
9.3 Application of Artificial Intelligence in Optimizing
Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109
9.3.1 Automation of Analyzing Transaction Behavior . . . . . . . 110
9.3.2 Network Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110
9.3.3 Automation of Adverse Media Search . . . . . . . . . . . . . . . . . 111
9.3.4 Automation of Narration for Case or Alert Closure . . . . 111
10 Ethical Challenges for AI-Based Applications . . . . . . . . . . . . . . . . . . . . . . 115
10.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115
10.2 Misuse of Personal Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116
10.3 Introducing Bias . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116
10.4 Bias in the Design of Machine Learning Algorithm . . . . . . . . . . . . 118
10.5 Ethical Challenges in Developing AI for AML . . . . . . . . . . . . . . . . 118
10.6 Ways to Avoid Bias in AI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119
xii Contents

11 Setting up a Best-In-Class AI-Driven Financial Crime Control

Unit (FCCU) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 121
11.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 121
11.1.1 Leadership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122
11.1.2 Organization Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123
11.1.3 Team Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126
11.1.4 Data Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126
11.1.5 Technology Set Up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127
11.1.6 Machine Learning Management . . . . . . . . . . . . . . . . . . . . . . . 128

Appendix 1: This Section Focuses on the Evaluation of Various

Machine Learning Techniques . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129
Appendix 2: List of Dimensions that Are Created as Derived
Variables for Model Development and Behavior
Analytics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137
Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 139
About the Authors

Abhishek Gupta possess over 18 years of experience in analytics driven advisory,

with focus on enterprise-wide risk management, forensics for financial crimes and
corporate strategy. Abhishek was also the risk management expert for McKinsey &
Co. and then with Sutra Management Consultancies, where he has successfully
worked with over 30 banks and financial institutions on Risk and Compliance
offerings, South East Asia, North America and Europe. Abhishek has been work-
ing with his team on new emerging technologies like text analytics, voice and
image analytics. Academically, he has also been one of the co-inventors of a pro-
visional patent on fraud management technology in India, authored few research
papers in reputed journals and has been a visiting faculty for MBA colleges.

Dwijendra Nath Dwivedi is a seasoned professional with over 19 years of exper-

tise in creating valuable propositions for analytics and AI. He holds a post-graduate
degree in Economics from Indira Gandhi Institute of Development and Research,
and he is currently pursuing a PHD from Krakow University of Economics in
Poland. He has presented his research at more than 20 international conferences
and has published numerous Scopus indexed papers on the adoption of AI across
various domains. As an author, he has made significant contributions to more
than 8 books and has published over 25 impactful articles in renowned journals.
Dwijendra conducts seminars and workshops on AI value for executive audiences
and power users. In his capacity as a thought leader, he actively bridges the gap
between business requirements and acts as a catalyst for enhancing analytical capa-
bilities. His efforts cultivate a culture of analytical thinking, which in turn drives
the development of effective business strategies.

Jigar Shah is a techno-management professional with 12 years of work experi-

ence into BFSI domain in business and analytics, consulting, IT services, project
management and private equity. He carries hands-on experience in executing chal-
lenging assignments and consulting clients in areas of financial risk, compliance,
and business intelligence. He has a rich experience in working with teams and
clients across geographies.

xiii
Acronyms

AML Anti-Money Laundering

API Application Programming Interface to integrate solutions
ATL Above the Line
BSA Bank’s Secrecy Act
BTL Below the Line
CAGR Compounded Annual Growth Rate
CCO Chief Compliance Officer
CDD Customer Due Diligence
CFT Combating Financing of Terrorism
CRS Common Reporting Standards
CTR Currency Transaction Report filed by a financial institution to the
central bank
e-KYC Know your customer by leveraging digital tools
ETF Electronically Traded Fund
EU European Union
FATCA Foreign Account Tax Compliance Act
FATF Financial Action Task Force
FBI Federal Bureau of Investigation
FCC Financial Crime Control
FinCEN Financial Crimes Enforcement Network
FIs Financial Institution
FIU Financial Investigation Unit
FTE Fulltime equivalent—used for measuring productive effort of one
human day
G-7 Group of seven countries
GDPR General Data Protection Regulation
GINI A coefficient ranging between 0 and 1 that provides indication of
predictive power
HNI High-net-worth individuals
IT Information Technology
KS Statistic A statistic ranging between 0 and 1 that provides indication of
predictive power
KYC Know Your Customer
MVP Minimum Viable Product
xv
xvi Acronyms

NBFC Non-Banking Finance Company

NLG Natural Language Generation
NLP Natural Language Processing
OCC Office of the Comptroller of the Currency
OFAC Office of foreign asset control
PEP Politically exposed person
Regtech Company specializing in technology for regulatory compliance
SAR Suspicious activity report filed by a financial institution to the
central bank
SME Small and medium enterprises
Overview of Money Laundering
1

1.1 Introduction

Money laundering is an act of disguising illegal or tax-avoided money and bringing

it into formal monetary channels. It primarily originates from two key sources.
The first is money generated from various criminal activities like drug trafficking,
human trafficking, bribery, or other illegal business. The second significant source
of money laundering is the funds from tax avoidance. Governments in several
countries impose a tax on income earned by individuals and non-individuals, such
as corporations and partnerships. There exist beneficiaries of this wealth who do
not want to pay their due taxes. They use multiple methods to avoid paying taxes
and resort to money laundering.
Over the last few years, financial institutions are increasingly tracking and
investigating another money stream, terrorist financing. Unlike money laundering,
participants of this activity have legally earned money. This money is routed to
terrorist organizations by sympathizers of the terrorists’ ideology.
As discussed, crimes are not new in this world and so is the mechanism that
people use to stash the money sourced by the wrongdoings. The unconfirmed
reports suggest the existence of money laundering before the advent of the formal
economy came into being. This was practiced by Chinese traders to avoid paying
taxes. A more formal form of money laundering has been prevalent since the
1930s in the USA. A big chunk of authors has mentioned Al Capone, who intends
to evade drug proceeds from the US authorities.
From the 1930s till the 1980s, there was a fair evolution of regulations, the focus
of regulators on launderers. It got prominence in the 2000s and in the last few
years, regulators are increasingly tightening their grip on not only the perpetrators
of these crimes. The regulators are also very severe on the financial institutions
that keep a blind eye on this category of customers and enable them while become
a part of this dirty money.

© The Author(s), under exclusive license to Springer Nature Singapore Pte Ltd. 2023 1
A. Gupta et al., Artificial Intelligence Applications in Banking and Financial Services,
Future of Business and Finance, https://doi.org/10.1007/978-981-99-2571-1_1
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