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GenAI falls flat as a RegTech anti-money laundering and compliance tool
By Nigel Morris-Cotterill  |  Dec 07, 2023
GenAI falls flat as a RegTech anti-money laundering and compliance tool
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Lawyer and financial crime risk and compliance specialist Nigel Morris-Cotterill explains why the GenAI being touted as the next wave in RegTech to keep VC funds flowing is in reality quite ineffective at financial risk analysis and anti-money laundering monitoring activities.

Location: No one knows, and very few can find out.

There is a current trend of regulatory technology (RegTech) companies marketing their products to technologically unsophisticated compliance officers, saying that they have improved performance by using ‘generative artificial intelligence’ (GenAI). One can easily see why this trend is developing: Venture capital is drying up for RegTech powered by ‘artificial intelligence’ (AI). Companies must therefore generate something new and exciting, a new wave for venture capitalists to ride before they find out that it is not a money pot, but a money pit.

With the already waning interest in ChatGPT, the race is on for companies to capitalize on GenAI. Across the spectrum of product development, there is a massive drive to incorporate GenAI into products while it is still ‘a thing’ - and this goes beyond RegTech. What if the entire global dataset were like the library down the street?

The reality is that GenAI is woefully indiscriminate in both its sources and its output. Like all computerized activity, it is not intelligent. In this case, it is simply algorithmic analysis of data with which it is provided or that it gets from sources where it is told to look - or, sometimes, not told not to look.

Think of the entire global dataset as if it is the small library down the street. There are many sections, some of which the librarian will direct one to when one is looking for something specific. Some sections are those that one will browse because one is not quite sure what one is looking for, but still hopes to come across it. There are also sections where, because of a pre-determined criterion, one is not permitted to enter.

When one finds information - which is all those ‘data’ are - one performs some function on it, either dismissing it or acting upon it. One might also eventually give up looking for it, and in doing so decide that it is not there or that

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