Paola Cristina Nunez Ameri, CRCO and AMLCO, at Citibank Europe: ‘Artificial Intelligence has arrived, our job is to implement it ethically and responsibly.’
The impact of artificial intelligence is imminent and undeniable, so it is necessary to highlight that it is not only part of our present but surely, of our future. Consequently, it is essential that it be properly regulated, highlight its benefits, and avoid a negative impact on society.
Artificial intelligence brings benefits that really make our lives easier. First, the improvement in efficiency translates into the automation of repetitive tasks and the time savings in the identification of patterns and anomalies; clearly, this allows for a quick response to potential problems. Second, proactive risk management is important to make decisions in a more effective and efficient way since you have access to data and/or information in real time. Third, the chance of error is exponentially lower as tasks are performed with better precision when analysing data, reporting, or monitoring.
As expected, just as there are benefits, there are also limitations or negative aspects to the use of artificial intelligence. First of all, until this matter is completely and correctly regulated, many ethical considerations will arise due to the lack of transparency on the origin of the information or data that we can obtain through the use of this technology. Then, some concerns arise in relation to the security and risk of AI systems, since they can store large amounts of confidential and private data, which makes them potential victims of cyber-attacks. Also, a situation of conflict of laws can be created; specifically, the main one would be with the data privacy Law since it is likely that the personal data of another person other than the person about whom the decision is made will be disclosed. Finally, small companies may be at a disadvantage in terms of access to these new technologies, as they have only a limited budget to implement AI in their system.
Every company is interested and willing to have a successful risk management program. One of the basic tools is to have a robust compliance department, in which the compliance officer plays an essential role. In my opinion, employees in charge of compliance should not only have the role of ensuring that companies and organisations fully act in accordance with legal regulations and industry-specific guidelines, but they should also have an intuitive understanding of the company’s objectives and culture. In my case, I am a lawyer by profession, which gives me added value, since I can use legal skills and abilities when interpreting and applying laws or making decisions and giving advice, however, it is not mandatory for the compliance officer to have a legal background. On the other hand, it is essential to be always in training, being informed, and in continuous development.
I have had the opportunity to attend some events related to Fintech and Compliance, in which I was able to present and exchange ideas with peers, technology vendors, and other event attendees, and we all agree that we still face a limitation in access to information. To give a clear example, we can talk about the necessary and mandatory documentation to comply with AML and KYC requirements, all vendors offer to provide you with any type of mandatory documentation in a short time and an agile manner, however the main source of all this information is one: the regulator. So, what happens in the event that the existing and available information is not updated? The information that third parties may provide us will not be the most current or correct, due to this circumstance, it will always be necessary to have a maker- checker process, in other words, the compliance officer has to verify that this information is really accurate. To give another example, a case could arise in which the compliance officer may know first-hand, through information provided by the client himself, of the existence of a discrepancy in certain documentation, which will require timely communication to the regulator and adequate correction and updating of information. It should be noted that until the information in the regulator's system is updated, the information that would still appear would no longer be the most current. In consequence, currently, artificial intelligence cannot completely replace the AMLCO function, but it should work hand in hand with people to achieve reliable and correct results since human intervention is essential to control, review, and approve all information or data that can be provided through this technology.
Various banks and financial institutions are adopting AI in diverse ways. On the one hand, some of them are super committed and open to innovation, which translates into million-dollar budget investments to implement various technologies in their system. On the other hand, some still maintain a cautious attitude: they continue to conduct research to ensure that they have a contained and well-chosen list of high-impact use cases and that they are allocating resources to them in the right way. As a third scenario, after an initial cautious approach, some banks have seen the need to adopt AI to remain competitive in the market, as they have had to recognise the transformative potential of AI, from coding and customer onboarding to fraud detection and compliance.
In conclusion, the main objective is to find the balance between ethical and responsible AI, which should always be implemented focusing on the human factor, which means combining human experience with emerging technologies such as AI, to ultimately offer the best product or service. Clearly, Artificial Intelligence is here to stay, so it is only expected that it be properly regulated and only bring the best benefits to society.
About Paola Cristina Nunez Ameri
CRCO (Country Risk Compliance Officer) and AMLCO (Compliance Officer AML)
I am a multilingual Peruvian lawyer with an international background.
Academic field: Bachelor's degree in corporate law from Pacifico Business School in Peru and two Master's degrees in France in International Business Law from UCLy and European Corporate Law from Paris Nanterre University.
Professional experience: Attorney in law firms in Peru, Legal counsel in international companies in France and Belgium, and Head of Compliance for financial institutions in Belgium.
About Citibank Europe
Citibank Europe Plc, Belgium Branch
Citi has had a presence in Belgium, enabling growth and economic progress, since 1919. The business lines are (I) Banking, Capital Markets, and Advisory, (ii) Security Services, (iii) Treasury and Trade Solutions, and (iv) Commercial Bank. Today, Citi Belgium's Institutional Clients Group (ICG) provides comprehensive financial solutions to its corporate and institutional clients in Belgium, which include major companies, financial institutions, public entities, and subsidiaries of foreign multinational companies.
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