The multi-regulator policy on technology improvements to AML programs was an “unprecedented step” and “great news for banks, who until now have been forced to use antiquated detection systems that generate tens of thousands of alerts each month with 90-plus percent false positive rates, and often fail to identify real crimes. I think the regulators clearly acknowledged that the existing systems just aren’t working, and they have to do something different. The new guidance will encourage new technology by making it clear that adoption will not necessarily trigger new liabilities for executives in general, and CCOs specifically.
A concern banks had was if they bring in this new technology, and it finds a bunch of bad stuff that they can’t find with existing systems, were they going to get in trouble? Were they going to come in and say, ‘Well, you should have found this stuff earlier?’ I think the regulators really understood those concerns. That is why this is really important guidance. They have recognized that banks struggle with legacy technologies that are not working.22 October 2020