OPPORTUNITIES ANDCHALLENGES OF NEWTECHNOLOGIES FOR AML/CFTJULY 2021
The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotespolicies to protect the global financial system against money laundering, terrorist financing and the financing ofproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-moneylaundering (AML) and counter-terrorist financing (CFT) standard.For more information about the FATF, please visit www.fatf-gafi.orgThis document and/or any map included herein are without prejudice to the status of or sovereignty over anyterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.Citing reference:FATF (2021), Opportunities and Challenges of New Technologies for AML/CFT, FATF, Paris, France,https://www.fatf-gafi.org/publications/ nges-newtechnologies-aml-cft.html 2021 FATF/OECD. All rights reserved.No reproduction or translation of this publication may be made without prior written permission.Applications for such permission, for all or part of this publication, should be made tothe FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France (fax: 33 1 44 30 61 37 or e-mail:[email protected])Photocredits coverphoto: Gettyimages
AcknowledgementsThe FATF would like to thank public and private sector stakeholders—includingtechnology developers, financial institutions and other experts—for providingvaluable input, case studies and feedback to this report.The work of this report was led by the FATF Secretariat (Inês Oliveira), withsignificant input provided by a Group of Experts from the following FATF delegations:Canada, Denmark, European Commission, Egypt, Germany, Israel, Italy, Japan,Malaysia, the Russian Federation, Singapore, United Kingdom, the United States, aswell as Europol and the Secretariat to the Eurasian Group (EAG) on Combating MoneyLaundering and Financing of Terrorism.
2 OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFTTable of contentsAcronyms . 3Executive Summary . 41.Introduction . 61.1. FATF Commitment to Responsible Innovation and Digital Transformation . 71.2. Scope and Methodology . 92.New Technologies for AML/CFT: towards a more effective implementationof FATF Standards . 112.1. Implementing the risk-based approach . 132.2. Financial Inclusion . 153.The Opportunities of New Technologies for AML/CFT . 193.1. Artificial Intelligence (AI) . 213.2. Natural Language Processing and soft computing techniques . 233.3. Distributed Ledger Technology . 263.4. Digital Solutions for Customer Due Diligence . 273.5. Application Programming Interfaces (APIs) . 314.The Challenges of Implementation of New Technologies for AML/CFT. 364.1. Regulatory challenges . 364.2. Operational Challenges . 404.3. Unintended Consequences and Potential for Abuse . 424.4. Assessing AML/CFT effectiveness of technology solutions and how to address residual risks . 445.Creating an enabling environment for the use of new technologies inAML/CFT . 465.1. Technologically-Active Supervisors. 485.2. Concluding remarks . 53Annexes . 54Annex A: Glossary . 55Annex B: Suggested Actions to Support the Use of Technology in AML/CFT . 60Annex C: Case Studies . 62Annex D: Additional RegTech case studies for the uses of new technologies forAML/CFT . 67References . 70 FATF/OECD 2021
OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR TFMVTSNLPNRAPEPPSCFSSBVASPArtificial intelligenceAnti-Money Laundering/Countering the Financing of TerrorismApplication Programming InterfaceCustomer Due DiligenceDeep LearningDistributed Ledger TechnologyDesignated Non-financial Business and ProfessionFinancial Action Task ForceMutual Evaluation ReportMoney Laundering/Terrorist FinancingMoney or Value Transfer ServiceNatural Language ProcessingNational Risk AssessmentPolitically Exposed PersonPrivate Sector Consultative ForumsStandard Setting BodyVirtual Asset Service Provider FATF/OECD 2021 3
4 OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFTExecutive Summary126.96.36.199.5.6.New technologies have the potential to make anti-money laundering (AML) andcounter terrorist financing measures (CFT) faster, cheaper and more effective. Theycan improve the implementation of FATF Standards to advance global AML/CFTefforts, ensure financial inclusion and avoid unintended consequences such asfinancial exclusion.As the global AML/CFT standard setter, the FATF is strongly committed to keepingabreast of innovative technologies and business models in the financial sector andto ensuring that the global standards remain up-to-date and can enable “smart”financial sector regulation that both addresses risks and promotes responsibleinnovation. Accordingly, the FATF reviewed the opportunities and challenges ofnew technologies for AML/CFT to raise awareness of relevant progress ininnovation and specific digital solutions. The FATF also looked at the persistingchallenges and obstacles to their implementation and how to mitigate them. Thisproject included the review and analysis of regulatory technology (RegTech) andsupervisory technology (SupTech), both of which can improve the effectiveness ofFATF Standards.Innovative skills, methods, and processes, as well as innovative ways to useestablished technology-based processes, can help regulators, supervisors andregulated entities overcome many of the identified AML/CFT challenges.Technology can facilitate data collection, processing and analysis and help actorsidentify and manage money laundering and terrorist financing (ML/TF) risks moreeffectively and closer to real time. Faster payments and transactions, more accurateidentification systems, monitoring, record keeping and information sharingbetween competent authorities and regulated entities also offer advantages.The increased use of digital solutions for AML/CFT based on Artificial Intelligence(AI) and its different subsets (machine learning, natural language processing) canpotentially help to better identify risks and respond to, communicate, and monitorsuspicious activity. At public sector level, improved live (real-time) monitoring andinformation exchange with counterparts enable more informed oversight ofregulated entities, helping to improve supervision. At private sector level,technology can improve risk assessments, onboarding practices, relationships withcompetent authorities, auditability, accountability and overall good governancewhilst cost saving.The report identifies challenges related to the development, adoption andapplication of these innovative solutions or practices. Many of these challenges aredue to outstanding operational and regulatory constraints, such as legacy AML/CFTcompliance systems and traditional regulatory frameworks and oversightmechanisms.The complexities and costs involved in replacing or updating legacy systems makeit challenging to exploit the potential of innovative approaches to AML/CFT for bothindustry and government. For industry, the cost-benefit analysis to adopt newtechnologies continues to be an obstacle to greater uptake of innovative solutionsfor AML/CFT, based in part on a real or perceived lack of regulatory incentives topursue innovation. Difficulties with the explainability and interpretability of digitalsolutions are another key challenge for both industry and regulators that in partstems from the limited availability of relevant expertise and a lack of awareness of FATF/OECD 2021
OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFT7.8.innovative technologies’ potential among AML/CFT professionals, both in industryand government. Increased communication and cooperation between the publicand private sector, informed by the type of information and analysis provided bythis report, together with an emphasis on responsible adoption of new technologiesand effectiveness, in particular with regard to data protection regulations, will bekey to overcoming these challenges and fully realizing the promise of responsibleinnovation to strengthen the effectiveness of AML/CFT measures.When used responsibly and proportionally, innovative AML/CFT technologies canhelp identify risks and focus compliance efforts on existing and emergingchallenges, but manual review and human input remains very important. Forexample, even in a technology enabling regulatory environment, human actors mustbe relied upon to identity and assess any residual risks presented by newtechnologies and put in place appropriate mitigation measures. Combining theefficiency and accuracy of digital solutions with the knowledge and analytical skillsof human experts produces more robust systems that can effectively respond toAML/CFT requirements whilst being fully auditable and accountable.The use of new technologies and innovation can help the public and private sectorsimprove the effectiveness of their risk-based implementation of the FATFStandards. The development, adoption and regulatory supervision of thesetechnologies must reflect threats as well as opportunities. It must also ensure thatthe use of innovative tools is compatible with international standards of dataprotection, privacy, and cybersecurity. FATF/OECD 2021 5
6 OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFT1. Introduction188.8.131.52.13.14.1The FATF Standards are a dynamic tool that evolves in response to changing globalmoney laundering and terrorist financing (ML/TF) threats, vulnerabilities andrisks, and to challenges that occur in their implementation. Thirty years after theirinitial adoption, customer due diligence (CDD) and related procedures have greatlyincreased the transparency of transactions and made it harder for criminals,terrorist financiers, and weapons proliferator financiers to misuse financialproducts. At the same time, although customer identification/verification andmonitoring is a key pillar of the AML/CFT framework, it continues to presentchallenges of implementation and effectiveness.Non-risk targeted CDD efforts can be perceived to be costly and inefficient, as theyconsume and often do not translate into accurate risk assessment processes orsmooth access to financial services. Recognising the accelerating pace of innovation,the profound impact of digital transformation on the financial system and the questfor greater effectiveness of FATF Standards, the FATF launched an initiative toexamine the potential of new technologies to mitigate ML/TF threats.For the purpose of this report, “new technologies for AML/CFT” 1 refers to:ainnovative skills, methods, and processes that are used to achieve goals relating tothe effective implementation of AMLCFT requirements orbinnovative ways to use established technology-based processes to comply withAML/CFT obligations.New technologies seek to improve the speed, quality, or efficiency and cost of someAML/CFT measures, as well as the costs of implementing the AML/CFT frameworkmore broadly, compared to the use of traditional methods and processes. Thetechnologies of greatest relevance are cross-cutting and enable new digital ways tocollect, process, analyse data. These technologies also allow to communicate dataand information via a variety of specific solutions. These capabilities can be appliedin overlapping ways and target a broad range of AML/CFT objectives. Many of thesenew technologies’ capabilities and implications are still largely unknown. That said,it is essential to understand their current capabilities and potential impact onAML/CFT.For example, digital identity solutions can enable non-face-to-face customeridentification/verification and updating of information. They can also improveauthentication of customers for more secure account access, and strengthenidentification and authentication when onboarding and transactions are conductedin-person, promoting financial inclusion and combating money laundering, fraud,terrorist financing and other illicit financing activities.As another example, natural language processing can support more accurate,flexible and timely analysis of customer information and reduce inaccurate or falseFor the purposes of this report the terms digital solutions, digital tools, innovative solutions orsystems are used interchangeably, and as appropriate, to mean new technologies for AML/CFTas defined in this paragraph. FATF/OECD 2021
OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFT15.16.17.information and enabling more efficient matching and search for additional data.Better and more up-to-date customer profiles mean more accurate riskassessments, better decision-making, and fewer instances of unintended financialexclusion.Likewise, Artificial intelligence (AI) and machine learning (ML) technology-basedsolutions applied to big data can strengthen ongoing monitoring and reporting ofsuspicious transactions. These solutions can automatically monitor, process andanalyse suspicious transactions and other illicit activity, distinguishing it fromnormal activity in real time, whilst reducing the need for initial, front-line humanreview. AI and machine learning tools or solutions can also generate more accurateand complete assessments of ongoing customer due diligence and customer risk,which can be updated to account for new and emerging threats in real time.However, AI/ML solutions vary greatly in both technology and use and may presentsignificant risks, which are discussed later in this report.Similarly, the adoption of innovative solutions, such as Application ProgrammingInterface (APIs) and Distributed Ledger Technology (DLT), data standardisation,and machine readable regulations can help regulated entities 2 report moreefficiently to supervisors and other competent authorities. The technologies alsoallow alerts, report follow-ups, and other communications from supervisors, lawenforcement, or other authorities to regulated entities and their customers, as wellas communications among regulated entities, and between them and theircustomers. The application of more advanced analytics by regulators can alsostrengthen examination and supervision, including by potentially providing moreaccurate and immediate feedback.The embrace of new technologies for AML/CFT compliance and supervision hasbeen impeded in some instances by concerns as to whether and how innovativetechnologies may be used under the FATF Recommendations, as well as undercountries’ AML/CFT regulatory frameworks.1.1. FATF Commitment to Responsible Innovation and Digital Transformation18.19.2As a global standard setting body (SSB), the FATF is committed to keeping abreastof innovative technologies and business models in the financial sector and ensuringthat the global AML/CFT standards remain relevant and effective in an environmentof accelerating digital transformation. This is so FATF’s requirements can enable“smart” financial sector regulation that helps drive responsible innovation tofurther both AML/CFT and financial inclusion objectives.The FATF formally endorsed responsible innovation for AML/CFT in a publicstatement issued in Buenos Aires on 3 November 2017, which declared:“The FATF strongly supports responsible financial innovation that is in linewith the AML/CFT requirements found in the FATF Standards, and willcontinue to explore the opportunities that new financial and regulatorytechnologies may present for improving the effective implementation ofAML/CFT measures.”For the purposes of this Report, ‘regulated entities’ refers to financial institutions, virtual assetservice providers (VASPs) and designated non-financial businesses and professions (DNFBPs),as defined under the FATF Standards. FATF/OECD 2021 7
8 OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFT184.108.40.206.The 2017 public statement built on the FATF’s prior efforts to support responsibleinnovation, while addressing potential illicit finance risks and the AML/CFTregulatory and supervisory challenges posed by emerging technologies. Thoseefforts include issuing numerous guidance and best practices papers, updating theRecommendations to address virtual assets (FATF, 2019), and extensiveengagement with the private sector through public-private workshops and theFATF Private Sector Consultative Forums (PSCF). 3Responsible innovation is supported through other international statements,namely the UN Security Council Resolution 2462(2019) (UN, 2019) which calledupon all States to enhance the traceability and transparency of financialtransactions, including through fully exploiting the use of new and emergingfinancial and regulatory technologies to bolster financial inclusion, and tocontribute to the effective implementation of AML/CFT measures.Despite the acknowledged benefits, the effective use of innovative technologies forAML/CFT has been limited by a variety of factors, impacting different regulatedentities and supervisors to different degrees.Making innovation one of its top priorities, the FATF German Presidency launcheda digital transformation initiative that includes three projects: 24.25.A study of opportunities and challenges for operational agencies, aimed atmaking systems to detect and investigate ML and TF and understandingML/TF risks, more efficient, andA stocktake on data pooling, collaborative analytics and data protection,aimed at helping the private sector improve their use of AI and big dataanalytics for AML/CFT and increase the efficiency of regulatorycompliance, while ensuring a high level of data protection.The FATF President has brought this agenda to international fora, emphasising itsimportance for a better implementation of the FATF Standards and AML/CFTeffectiveness. (FATF, 2020)This report aims to: 3The study underlying the present report, examining the opportunities andchallenges of new technology to make implementing AML/CFT measuresby the private sector and supervisors more efficient and effective;Increase awareness of and identify opportunities to leverage newtechnologies and emerging and existing technology-based solutions;Identify the conditions, policies and practices that can help support thefurther adoption of new technologies that contribute to the efficiency andeffectiveness of AML/CFT efforts in line with jurisdictions’ regulatoryregimes, illustrated by case studies;Examine regulatory obstacles or other factors impeding the successfuladoption of new technologies and where relevant, propose additionalFATF projects to explore potential policy responses; andMany of FATF’s positions, engagement and relevant documents on FinTech and RegTech maybe found at the FATF FinTech & RegTech Initiative website. Available at: ech/. FATF/OECD 2021
OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFTProvide a common set of definitions, conceptual framework and suggestedactions for government authorities and private sector stakeholders toadvance the responsible development and use of new technologies forAML/CFT.1.2. Scope and Methodology220.127.116.11.30.31.This report focused on the ways in which new technologies may assist jurisdictionsand regulated entities become more effective in the implementation of AML/CFTstandards. In particular, digital solutions which enable a better understanding,assessment and mitigation of risks, customer due diligence and monitoring, andcommunication with supervisors may assist achieving effectiveness in theimplementation of AML/CFT standards.The report addresses the implementation of new technologies known as RegTech 4,such as AI, machine learning, big data, and advanced cognitive analytics/algorithmstargeting customer identification and verification requirements, and broaderAML/CFT compliance obligations. The project also considers SupTech 5 ortechnologies used by supervisory agencies, for example, risk assessment tools, datavisualisation tools or others. (Coelho et al., 2019)This report’s research considers, where technologies have been deployedsuccessfully, what were the preconditions which enabled their effective use, whatwere the benefits achieved, and what, if any, new requirements resulted from thesuccessful use of innovative solutions?The report also considers cases where promising technologies have not beensuccessfully deployed and identifies challenges or obstacles to their effective use. Italso explores whether coordinated global action is needed to enable greater use ofinnovative technology based solutions to support AML/CFT objectives. Thisincludes analysing structural challenges, e.g. issues of data quality, changing legacysystems, cost constraints and the lack of regulatory incentives.Where these technologies offer real benefit and help to respond to threats in aneffective manner, FATF analyses use-cases from early-adopters of newtechnologies, to enable other regulated entities and authorities to implement themin the most effective way.Examples of other technologies relevant to the better implementation of FATFStandards not proposed for analysis in this report include: 45Data management and sharing toolsAnalytic tools including the use of machine learning and big data analyticsby FIUsRegTech is a sub-set of FinTech that focuses on technologies that may facilitate the delivery ofregulatory requirements more efficiently and effectively than existing capabilities, as referredto in Feedback Statement FS16/4, Financial Conduct Authority, Call for Input on Supporting fSupervisory technology (suptech) is the use of innovative technology by supervisory agenciesto support supervision. See, (Broeders D. and Prenio J., 2018) FATF/OECD 2021 9
10 32.33.6OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFTThis report relies on general desk-based research and responses to an online digitaltransformation Questionnaire 6 which the FATF Secretariat disseminated togovernment authorities and public and private sector experts. The Secretariat alsoconsulted with key stakeholders to obtain additional information and expert views,including at a High-Level Roundtable on the Opportunities and Challenges of NewTechnologies for AML/CFT held virtually by the FATF on 10 of March, 2021.The FATF Digital Transformation questionnaire sought stakeholders’ views on themain users (adopters) of new technologies, the purposes and added value of giventechnology-based solutions under the jurisdiction’s AML/CFT and other regulatoryframeworks. It also focused their impact on users’ relationships with thesupervisors and obstacles to implementation, and the relationship of newtechnologies to the FATF Standards and other regulatory frameworks. It alsoencouraged respondents to submit case-studies illustrating best practices and/orspecific challenges. 54% of respondents identified as private sector representatives,mainly large banks and technology developers. At public sector level, the majorityof responses were submitted by supervisors.The Questionnaire sought information on the opportunities and challenges of new technologiesfor this project. It collected 188 responses, including case-studies and examples of digitalsolutions’. FATF/OECD 2021
OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFT 2.New Technologies for AML/CFT: towards a more effectiveimplementation of FATF Standards18.104.22.168.38.39.7One of the main challenges hindering the effective implementation of AML/CFTmeasures is poor understanding of ML/TF threats and risks. Decision-making,based on inadequate risk assessments is sometimes inaccurate and irrelevant,relying heavily on human input and defensive box-ticking approaches to risk, ratherthan applying a genuinely risk-based approach.The inability to adequately identify, assess and mitigate money laundering andterrorist financing risk, including the fundamental elements of risk identification(customer identification/verification and monitoring of transactions) poses anobstacle to effectiveness in AML/CFT. This is where new technologies can providethe most added value.The majority of current risk assessment and risk management efforts are based ona combination of automated but static analyses of a pre-determined set of riskfactors, together with human judgement. Legacy systems 7 are updated with newalgorithms and manually inputted information, generating matrixes for riskinterpretation and action, but these very rarely offer a real time overview ofcustomer transactional or institutional risks.Moreover, traditional risk assessment tools, based on spreadsheets (such as Excel)or static reporting platforms, do not allow data to be analysed at a large scale,limiting the potential for correlations and analysis to generate a more fine-grainedpicture of the risks. In addition, the quality of the data obtained by legacy systemsvaries and may not offer the accuracy and detail required to comply with AML/CFTstandards.In the private sector, poor risk assessment can lead to a defensive box-tickingapplication of the AML/CFT framework, which is inefficient and burdensome, andmore importantly does not reflect the real ML/TF threats to the institutions. Poorrisk assessment undermines a genuine risk-based approach to decision-making andprotecting the integrity of the financial system. This potentially contributes to twodistinct problems - lack of sufficient attention to mitigating new or emerging risks(allowing ML and TF to take place), and over-application of risk mitigationmeasures in low-risk situations where simplified measures may be appropriate(causing unnecessary costs and friction to customers, including financial exclusion).The use of new technologies in the identification, assessment and management ofML and TF risks allows risk analysis to be more dynamic, provide network analysis,and operate at customer, institutional, jurisdictional and cross-border levels (SeeBox 1). However, optimal use of these tools requires a regulatory and policyenvironment that frames adequate data pooling and sharing, or collaborativeanalytics, as well as appropriate access by supervisors and law enforcement.For the purposes of this paper “legacy systems” refers to the systems and practices that rely onlow-tech (manual submissions and databases) processes for data collection and analysis. FATF/OECD 202111
12 OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFTBox 1 Dynamic risk assessment tool for FIsA multinational FI is building a Dynamic Risk Assessment tool to: Use data with greater depth and richness updated dynamicallyto reflect the latest investigative insights.Identify financial crime risk at a faster pace and with lessunproductive alerts.Create more accurate and sophi
1. New technologies have the potential to make anti-money laundering (AML) and counter terrorist financing measures (CFT) faster, cheaper and more effective. They can improve the implementation of FATF Standards to advance global AML/CFT efforts, ensure financial inclusion and avoid unintended consequences such as financial exclusion. 2.
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