WM Market Reports
Kickstarting KYC: Faster, Deeper Client Due Diligence
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Applying Artificial Intelligence in Wealth Management: Compelling Use Cases Across the Client Life Cycle. This is part of a series of articles drawn from a major report of this title that is produced by this news service.
Wendy Spires, Head of Research at WealthBriefing, discusses
how the “digital detective work” AI can carry out will make
client due diligence a very much more efficient – and far less
risky – affair for wealth managers. (To
view the full report via a registration link and URL, click
here.)
As previously discussed, wealth management advisors should really
be looking forward to their work being facilitated by AI, rather
than fearing replacement by it. However, it seems certain that AI
- in combination with other new technologies - will indeed cut a
swathe through compliance.
Since 2011, US and European banks have been hit with $150 billion
of litigation and conduct charges. As regulation has ratcheted
up, the scramble to avoid censure has seen many institutions
double their compliance headcount. Currently, financial
institutions have to dedicate 10-15 per cent of staff to
governance, risk management and compliance and regulation is now
estimated to cost the industry an eyewatering $270 billion yearly
and as much as $1 billion per firm.
Valiant efforts have been made with outsourcing and labour
arbitrage, but we are only at the beginning of a huge wave of
regulatory automation that will sweep the sector. “Industry
observers agree that more compliance functions will become
automated over the next 3-5 years as regulations themselves
become more complex, multi-modal and extra-territorial in
outlook,” said Dr Anthony Kirby, Associate Partner, Regulatory
and Risk Management - Regulatory Intelligence at EY in the
UK.
The potential to simultaneously slash costs and business risks
through regtech is increasingly becoming too compelling for
institutions to ignore – particularly given the added chance to
vastly improve the client experience.
Relieving onboarding pain
Much previous WealthBriefing research has focused on the
acute challenges in the client discovery and take-on phase for
investors, advisors and institutions. Onboarding is often
inordinately lengthy and onerous due to a lack of digitalisation,
leading 71 per cent of wealth managers to fear clients dropping
out during the process.
Client due diligence obligations have become increasingly weighty
amid the global crackdown on financial crime and are the source
of much of this pain (wealth managers have estimated that
screening high-risk clients requires an average of 5.4 hours of
work and even low-risk ones 1.6 hours).
They have therefore become a big regtech focus. Some 63 per cent
of wealth managers globally foresaw increased spend in this area
in 2017, but with 44 per cent opting to concentrate on technology
investment rather than throwing (ever-more expensive) personnel
at the problem. And, with the advent of AI applications for Know
Your Client (KYC) and Anti-Money Laundering (AML) purposes,
wealth managers’ reliance on technology in these labour-intensive
and high-risk areas seems certain to rapidly accelerate.
So, how can AI technologies help make client discovery and
documenting due diligence both better and more efficient?
As our experts observed, the vast majority of prospective clients
will present no real compliance issues that will call for
escalation to a human expert, so there is great scope to automate
the collation of all evidence required to onboard them.
Documenting sources of wealth/funds constitutes a major headache
for firms, while for clients the questioning required to open an
account can feel intrusive and laborious.
AI technologies can ensure they are only asked what is strictly
necessary and facilitate an element of “self-service” (and
depersonalisation) that might be very helpful in fledgling
relationships. Importantly, 38 per cent of clients already prefer
to open accounts digitally today, with this expected to rise to
52 per cent in the next few years.
As David Teten, Managing Partner of HOF Capital, argued: “Client
onboarding is an extremely cumbersome and manual process that
could be improved by new technologies in many ways. For example,
implementing Robotic Process Automation can streamline KYC
decision-making through more interactive and intuitive
information-gathering. AI can also be a great help in mining
public data sources to find out things like the value of a
client’s home or of the company they sold.”
Although most clients are unproblematic from a compliance
perspective, it must also be remembered that wealth management is
by definition a highly cosmopolitan industry assisting clients
with complex, international financial affairs. Here, AI can be
invaluable in ensuring that all clients who can be onboarded,
are, and that riskier ones do not slip through the compliance
net.
Digital detective work
Just as in lead generation and news personalisation, one of
the most powerful ways AI can be applied in a client due
diligence context is in using Natural Language Processing (NLP)
to “read” vast amounts of information in any language. “AI can be
a great help in the onboarding phase, through intelligent
document scanning and sifting through the array of external data
sources wealth managers should be consulting,” said Alessandro
Tonchia, Co-Founder of Finantix. “As well as massively reducing
risk, it can hugely improve sales effectiveness and enhance the
client experience.”
As Tonchia explained, the real power of the technology lies in
its ability to intelligently extract risk-relevant facts from a
huge volume of data, but then to also synthesise and deduplicate
that information so that it is both meaningful and
concise.
“Before, the technology might have flagged a hundred mentions of
an individual doing business with North Korea, but now it will
collapse those hundred documents into a single ‘red flag’ alert,”
he said. “NLP can also discern the difference between a person
having, say, starred in a film about terrorism and them having
been actually linked to it. Eliminating false positives and
irrelevant results makes analysing true risk a much easier
task.”
In addition to summarising information, the massive reach of AI
analyses can also uncover risk indicators that it would take an
inordinate amount of detective work to uncover manually.
“One area where we’re really adding value is in network
analysis,” Tonchia continued. “Here, a prospective client might
present as totally clean, but we could discover that in fact they
sit on the same board of directors as a very dubious individual,
or that they are an advisor to a company that has a joint venture
with a sanctioned entity, for example.
“It’s about detecting third-level relationships and indirect
risks to mitigate all conceivable risk factors. Criminals and
sanctioned companies are, after all, unlikely to act in the open
to try to open an account with you.”
The power of many of the AI applications explored in this report
lies in Machine Learning (that is, where systems learn and
improve from experience). But the sophistication of Finantix’s
technology goes beyond even this in the ever-evolving fight
against financial crime.
“You need to not only define an individual’s network of
relationships, but also to navigate and make inferences about the
connections,” he said. “We’re now going beyond Machine Learning
and investing heavily in reasoning tools and inference engines
that emulate the ‘thinking’ of a human investigator.”
Barriers beginning to come down
The terrorist threat and a series of money laundering scandals
are ensuring that the fight against financial crime remains
absolutely top of the international agenda, while at the same
time clients are growing increasingly intolerant of inelegant
consumer experiences – no matter how good the regulatory
rationale. Combined, these factors make compliance - and client
due diligence in particular - among the areas most ripe for AI
amelioration. And this must surely be right around the
corner.
Regtech solutions are still evolving, but, according to EY’s Dr
Kirby, the main brake on adoption is that “the IT environments at
regulators, central banks and governments are not yet at the
point where they can readily interoperate with the industry as a
whole”. However, he sees this rapidly changing as regtech
solutions and “smart” or self-executing contracts become more
mainstream (these are computer programming codes that facilitate
or enforce the performance of an agreement using blockchain
technology).
“Machine Learning, Artificial Intelligence and Natural Language
Processing will quite soon be widely applied to the ‘second line
of defence’ skills in legal, compliance and risk management,” he
said. “This will start with day-to-day monitoring in activities
such as surveillance and AML and extend over time to filing
reports of trades and transactions to meet regulatory conduct of
business and prudential obligations in each jurisdiction.”
Believing them beneficial to society as a whole, as well as to
the institutions pooling their resources, regulators and
governments are thought to be increasingly positive on the use of
“utility technolo¬gies” (this is where service/technology
providers offer a centralised outsourcing of key common tasks,
potentially across the entire industry). In an AML context, this
would mean institutions and authorities sharing KYC,
transactional or other data through a third party “utility” - an
approach which would likely have to draw on Distributed Ledger
Technol¬ogy in turn.
Compliance is undeniably the area most fraught with complexity
when it comes to AI adoption, and great strides in other
technologies such as biometrics and big data will also be
required for real progress to be made. However, it is also
arguably where wealth management sector stands to make the
biggest gains. For many institutions, the compliance burden has
become unbearably heavy and, as we have seen, AI has huge
potential to help lighten the load.