2. A.I.-driven automationA.I.-driven automation
• New regulatory standards and expectations
• Additional requirements: UBO’s, tax, counterparties,
• Secondary Sanctions
• Manual on-boarding processes
• Competitive market requiring fast processes
• Create conditions for growth without being hampered by compliance
• Sub-par processes, lack of technology, point solutions
• New types of investors, complex corporate structures
Challenges
3. A.I.-driven automationA.I.-driven automation
Investments due diligence
• Types of entities to verify:
• sponsors, target, beneficiary, participant, tenants, guarantors, other linked parties,
directors, managers
• Intermediaries: Security Agent / Agent Bank / Notary / Lawyers etc…
• +/- 50 entities to perform diligence on per project
• Types of documents to collect:
• Certified copies of group org chart, incorporation, directors, trustees, passports,
shareholders , UBO’s, authorised signature
• letters from chief compliance/ CFO concerning status
• Extract from commercial and official registers, articles of association
• Audited accounts, tax compliance letter for no aggressive tax structuring
• Fatca, CRS self certification
• …
• Types of scoring:
• tax crime, financial crime, sanctions, AML, secondary sanctions
• Enhanced due diligence
• Average duration: 2 months to completion for investor or project due diligence
4. A.I.-driven automationA.I.-driven automation
Speed, effectiveness, efficiency, cost….
Client Stated Objectives
***** experienced tremendous regulatory pressure to improve their regulatory compliance and risk
effectiveness. ****’s stated objectives are as follows:
• Improve regulatory compliance across ****’s various lines of business and geographies
• Provide flexible solution(s) for evolving regulatory demands and differences across regional jurisdictions
including:
• Support governance and mitigate operational compliance risk, by ensuring consistency and accuracy of
GFCD activities through workflow, governance, and transparency
• Support integration with downstream and upstream systems
• Enable globally consistent and locally effective solution(s) to standardize financial crimes compliance
activities throughout
• Enhance process efficiency through the automation of manual processes and elimination of duplicative
activities
• Enable configurable workflows and interfaces; and
• Support new and emerging technologies
6. A.I.-driven automationA.I.-driven automation
Corporates Score : Qualification of the corporates
01
Corporates &
Sanction lists
Profile of the
corporate :
Shareholding,
legal form,
business line, ..
UBO /
national PEP
/ foreign PEP
A positive
matching is
sufficient to
increase the pace
of the monitoring
Alerts are
qualified in real
time and integrate
the result into the
score
UBO /
sanction list
02 03 04
7. A.I.-driven automationA.I.-driven automation
Score based on following criteria
• Private Customer/ legal entity (coporate)
• Operation or transaction (remittance, redemption)
• Origine and destination of funds,
• Country risk
• Justification of the operation
• distinction between subscriber and payor
• Client channel (broker, online, branch, partner…)
Operations & transactions Risk Scoring
Example based on the French Insurance Regulators (ACPR) guidance
Providing a spreadsheet & note describing the
principles of the score
The operation or transaction score can be
intergrated into a business rule integrated in
your workflow and trigger alerting
8. A.I.-driven automationA.I.-driven automation
Pre-contractual 01
02 04
03 05 At the termination of the
relationship
Periodic reviews
Remediation,
At acceptance
At the occasion of a transaction or a
significant event
An obligation since the Third EU Directive
The ongoing due diligence
9. A.I.-driven automation
Examples of A.I.-drive automation micro services
Making onboarding processes faster, more efficient, more effective
Up-to-date certified copy of the Group organisational chart + expected post-closing(Up-to-date means including any potential new entities involved in the deal) Certificate of incorporation / Extract from Commercial Register Certificates of all name changes where applicable Memorandum of Association / Articles of Association (Executed version) Latest audited financial accounts Up-to-date certified list of all directors / Trustees Up-to-date certified copies directors’ passports Up-to-date certified list of shareholders in the company.Copy of the commercial register and a list of shareholders / share register for each company “above” the borrower(s) Identification documents of ultimate shareholders holding 25% or greater or an AML letter from the Compliance Officer / Finance Director / Administrator confirming status that there are no beneficial owners holding 25% or more Please provide a confirmation from the tax advisor that the post-closing structure is compliant with the applicable tax regulation in order to give us the evidence there is no aggressive tax structuring Up-to-date certified true copy of the authorised signature list (names and specimen signatures)