Using Automation and AI toCombat Money Laundering

Money laundering, which is the criminal activity of processing criminal proceeds to disguise their origin is one of the gravest problems faced by the global economy, and its size is growing rapidly. It is estimated that 2- 5% of the global GDP or US$800 billion to US$2 trillion is being laundered every year across the globe.

Banks have begun to understand that their legacy rules-based systems cannot effectively mitigate risks related to money laundering. There is a need to embrace advanced technology that can effectively solve their problems of getting involved in money laundering cases. This white paper outlines a case study focusing on the effectiveness and limitations of Artificial Intelligence (AI) in detecting and preventing money laundering activities. It will provide an overview of the design, architecture, implementation, and testing of such a strategy.

ESG Greenwashing And Applications of AI For Measurement

“ESG greenwashing” refers to the strategic communication tactics firms use to
selectively disclose their ESG conduct to stakeholders.

ESG greenwashing strategy, while it may attract and satisfy stakeholders at the beginning, may cause different issues for firms later, such as adverse publicity, lobbying, or boycott campaigns by consumer or pressure groups or divestment by socially responsible investors. The complex impacts of ESG
greenwashing underscore the imperative of discerning and quantifying instances of such practices. We aim to consolidate recent literature reviews of ESG greenwashing, methodologies to measure ESG greenwashing and developing applications of AI, text analysis and machine learning models to advance such measurement.

This white paper makes significant contributions to policy developments, such as the greenwashing regulations of the UK FCA and the European Parliament.

Simplifying Compliance through Explainable Intelligent Automation

We discuss how explainability in AI-systems can deliver transparency and build trust
towards greater adoption of automation to support financial regulation compliance among
banks and financial services firms.

We uniquely propose the concept of Explainable Intelligent Automation as the next generation of Intelligent Automation. Explainable Intelligent Automation seeks to leverage emerging innovations in the area of Explainable Artificial Intelligence. AI systems underlying Intelligent Automation bring considerable advantages to the task of automating compliance processes. A barrier to AI adoption though is the black-box nature of the machine learning techniques delivering the outcomes, which is exacerbated by the pursuit of increasingly complex frameworks, such as deep learning, in the delivery of performance accuracy.

Through articulating the business value of Robotic Process Automation
and Intelligent Automation, we consider the potential for Explainable Intelligent Automation
to add value. The solution framework sets out the Explainable Intelligent Automation
framework, as the interface of Robotic Process Automation, Business Process Management
and Explainable Artificial Intelligence. We discuss key considerations of an organisation in
terms of setting strategic priorities around the explainability of AI systems, the technical
considerations in Explainable Artificial Intelligence analytics, and the imperative to evaluate
explanations.

Explainable AI For Financial Risk Management

We overview the opportunities that Explainable AI (XAI) offer to enhance financial risk
management practice, which feeds into the objective of simplifying compliance for banking and
financial services organisations. We provide a clear problem statement, which makes the case for
explainability around AI systems from the business and the regulatory perspective.

A comprehensive literature review positions the study and informs the solution framework proposed. The solution framework sets out the key considerations of an organisation in terms of setting strategic priorities around the explainability of AI systems, the institution of appropriate model governance structures, the technical considerations in XAI analytics, and the imperative to evaluate explanations.

The use case demonstration brings the XAI discussion to life through an application to AI based credit risk management, with focus on credit default prediction.

Financial Regulation Innovation Lab – Exploring the intersection of quantum computing and the finance sector

As part of the 4th FRIL theme focusing on innovation to address financial crime, the FRIL team  along with Alliance for Research Challenge in Quantum Technologies (Quantum ARC) and Technology Scotland hosted a roundtable to explore and catalyse the opportunities present now and in the near-future between quantum computing and the finance sector.

The discussion spanned a broad range of topics at the intersection of quantum and finance, with various opportunities and risks highlighted. Within these opportunities and risks, the discussion emphasised the critical need in thinking in relation to economic crime and fraud, which we look forward to progressing through the 4th FRIL programme currently live focusing on ‘innovation to address financial crime’.

What is Quantum Technology and the risks it presents?

McKinsey states quantum technology could create value worth trillions of dollars within the next decade with the finance sector identified as a sector that could see the earliest impact, however the concept remains relatively unknown to most. The term quantum technology broadly relates to science that applies quantum mechanics to a given field of technology, and refers to a subset of fields such as quantum computing, quantum sensing, quantum imaging, or quantum communications.

For the purposes of this blog, we will be focusing on quantum computing, which utilises qubits, concisely summarised by the World Economic Forum as –

Quibits are the equivalent of a classical bit, and the most fundamental unit for encoding information. Where a bit can be in a state of either on or off (0 or 1), a qubit can be in either 0 or 1 – or a combination of both. This is because of a superposition effect in quantum theory, which means that particles can exist simultaneously in multiple states. 

In practice, this means not only can quantum computing provide a significant performance boost in processing, but it also has the potential to solve complex problems much faster than even the most powerful supercomputers today.

Whilst this kind of revolutionary power could deliver numerous opportunities for the finance sector, the risk rapidly materialises when considering public-key cryptography (PKC), which the security of nearly all Internet communications today is based on. The underpinning security of PKC relies on the difficulty of the mathematical problems and the challenge in which classical computers have in solving them. However, solving these mathematical problems with a general purpose quantum computer is considered easy, with Shor’s algorithm demonstrating this capability back in 1994, the challenge being that the power capabilities of a quantum computer to run the algorithm do not yet exist.

As highlighted by the NCSC, although advances in quantum computing technology continue to be made, quantum computers today are still limited, and suffer from relatively high error rates in each operation they perform. For organisations, however, this risk remains a priority for the thinking of today as bad actors are adopting a ‘harvest now, decrypt later’ approach to collect valuable, sensitive data in anticipation of power capabilities being on the horizon.

What is the current regulatory landscape at the intersection of quantum computing and the finance sector?

Regulatory agencies worldwide are battling with the balance between technology readiness levels and appropriate regulation or standard setting in relation to developments.

In October 2024, the UK Govt agreed with recommendations made by the Regulatory Horizons Committee (RHC – commissioned by DSIT to review the future needs of quantum technologies regulation to support innovation and growth) ‘that it is too early to establish regulatory requirements and legislation for quantum technologies at this stage given the nascency of the sector, but sustained action is required now to increase regulatory capability and enable a sector- and application-specific approach to regulating quantum technologies in the future’. When considering the finance sector specifically, the UK’s Financial Conduct Authority has demonstrated its position as a leading voice in the quantum security domain through collaborative initiatives with the World Economic Forum, where research was published offering guidance for businesses and regulators to ensure a collaborative and globally harmonised approach to quantum security.

Looking further afield at the international landscape, momentum continues to evolve at pace, and earlier this year we also saw the US agency National Institute of Standards & Technology (NIST) finalised several post quantum encryption standards. With these standards, NIST encouraged large organisations, including those across the finance sector, to begin transitioning to the new standards as soon as possible. Regulatory authorities in Singapore have also recently launched a ‘Quantum Track’ within their Financial Sector Technology & Innovation Scheme (FSTI 3.0), with an additional S$100 million earmarked to support innovation in quantum and AI.

Despite this progress, participants in the discussion broadly agreed there is still a long way to go when assessing the regulatory and standard setting landscape of quantum.

How can we collectively progress successful collaboration around the exploration of quantum technologies?

The consensus of the discussion emphasised that the fundamental principles for continued collaboration span across the triple helix of engagement from industry, academia and regulatory colleagues, mirroring the principles that underpin the Financial Regulation Innovation Lab. Here at FRIL we will continue to actively convene stakeholders across these groups on topics that present both opportunities and risks in financial regulation, exploring how innovative propositions and ways of working can be progressed across the ecosystem.

Across the FinTech Scotland cluster there are various collaborative projects exploring the beneficial and responsible exploration of quantum technologies. One of which, highlighted by roundtable attendees, is the BT Quantum Key Distribution project. The NCSC outlines that Quantum Key Distribution (QKD) mitigates the quantum threat to key agreement using properties of quantum mechanics, rather than hard mathematical problems, to provide security. We look forward to continuing to engage with our partners in the BT team on their learnings throughout this programme and sharing insights across the cluster.

Challenges were highlighted around accessing and sharing data, which continues to be a barrier for innovators and researchers in this area. Discussion touched on the potential of synthetic data in aiding progress for development activities, and reference to the success of regulatory initiatives such as the FCA Digital Sandbox in already going some of the way to knock down these barriers. Risks were also highlighted around the danger that advancements in quantum could be dominated by existing major players in the market, further emphasising the importance of initiatives that support democratising the playing field for innovators in this space to enable competition and avoid monopolisation.

What’s next in the intersection of quantum and finance? 

Reflections were made on the rapid evolution of AI, and the opportunities to respond differently as we look forward to the evolving risks and opportunities that quantum presents. These lessons range from the debate around explainability, and the potential opportunities quantum presents in this field, through to the pace at which regulation and standard setting is struggling to keep up with the technology.

There was a broad agreement across attendees that priority use cases for the finance sector in regards to quantum computing need refinement, with possibilities spanning from the use of quantum technologies by bad actors through to organisational adoption of quantum technologies. Attendees also highlighted the opportunities that can be explored with quantum technology as we look to areas such as open finance and the value that can be derived from this data to create beneficial and responsible innovation.

The FRIL Innovation to Address Financial Crime programme lays the foundations to begin testing some of this thinking, as evidenced through the roundtable and also the broader innovation call series, and we will continue to engage with experts across the ecosystem in the long term roadmap of FRIL focus areas. We are looking forward to engaging with innovators across the industry led use cases in this programme, exploring where potential quantum computing advancements may provide opportunities to more effectively tackle financial crime risks.

Interested in exploring more? The key contacts across the Financial Regulation Innovation Lab on this topic are:

Consumer Duty and Innovation with NatWest

Season 4, episode 12

Listen to the full episode here.

In this episode we’re diving into the Consumer Duty Regulation and the opportunities that outcomes-based regulation opens for innovative solutions that can enable financial services to maximise positive outcomes for all customers and in turn create economic and social growth.

The Financial Regulation Innovation Lab has launched its third innovation challenge focusing on that topic with 14 financial services partners ranging from banks, building societies and credit unions. 

NatWest have been a keen supporter of this challenge seeing to harness the brightest ideas in fintech and to bring industry together on this key topic.

Today, we’ll explore what this means for financial services organisations, for the millions of people across the country who are customers of Financial Services firms and how innovation and ambitious fintechs are already making a difference.

With: 

Will Kerr, Head of Customer Outcomes

Samantha Brand Customer Lead Innovation & Partnerships

The landscape of financial fraud in the UK

Season 4, episode 11

Listen to the full episode here.

This is the inaugural episode of a special FinTech Scotland Podcast Series, co-hosted with with Charlotte Moir fromBT.

This episode highlights the launch of the new FinCrime Innovation Programme, tackling the pressing issue of fraud and financial crime.

We’ll unpack the impact of fraud in 2023, with £460 million lost to APP fraud in the UK, and discuss the implications of the new PSR mandatory reimbursement scheme introduced in October 2023. This landmark change enforces stricter rules within Faster Payments, ensures a shared responsibility between payment firms, and provides enhanced protections for customers, especially the vulnerable.

Our guests bring diverse insights into the fight against fraud:

• Lauren Cassells, Research & Programme Innovation Manager at FinTech Scotland, discusses the collaborative efforts of the FRIL initiative and its industry-wide engagement.

• Brian Webb, Chief Security Officer for Consumer at BT, shares BT’s strategies in combating fraud and fostering innovative partnerships.

• Paddy O’Keefe, Economic Crime Public & Private Partners Manager at Virgin Money, explores Virgin Money’s initiatives to ensure comprehensive fraud reporting and prevention.

Financial firms, Telcos and Technology leaders launch a collaborative programme in International Fraud Awareness Week to tackle financial crime across the UK

As part of International Fraud Awareness week, 11 industry partners including BT, HSBC, Morgan Stanley, Abrdn, TSB, Virgin Money, Lloyds Banking Group, Barclays, Fujitsu, Equifax and Dudley Building Society are collaborating to launch an innovation programme focused on addressing financial crime.

FinTech Scotland, SuperTech West Midlands, and Greater Manchester Combined Authority, brought together through the Innovate UK Innovation Accelerators programme, will lead the UK wide innovation call aiming from within the Financial Regulation Innovation Lab to tackle financial crime challenges.

Innovators worldwide are invited to apply to join the programme by 13 January 2025. Successful applicants will benefit from direct support from industry leaders, an unparalleled opportunity to refine and test their propositions within a robust framework. Participants will also gain insights through exclusive roundtables, masterclasses, and workshops led by leading academics from the University of Glasgow, University of Strathclyde, Aston University, and Birmingham City University.

This initiative builds on the momentum of three previous innovation calls launched this year by FinTech Scotland through its Financial Regulation Innovation Lab (FRIL). By publishing industry-led challenge statements, FRIL invites innovators to develop new solutions to address real world challenges. By focussing on non-competitive challenges, FRIL encourages collaboration across established institutions, delivering meaningful change in financial services and other sectors.

In addition, this fourth call further expands the geographical reach of FRIL. Having expanded recently on the call relating to Consumer Duty, launched in September, with the partnership with SuperTech West Midlands, the financial crime programme welcomes the addition of Greater Manchester Combined Authority to cement the development of FRIL as an asset for the whole of the UK.  As the three geographies with Innovation Accelerator pilots, part of the government’s commitment to place-based innovation investment through Innovate UK, part of UKRI, the partnership is working to demonstrate the power of this approach and that of cluster-led innovation activity relevant to advancing the UK’s position in a priority sector

This collaboration will deepen FRIL’s impact in tackling financial crime, with a specific focus on five use cases provided by industry.

The call will conclude on 20 March 2025 with a showcase event, offering innovators the chance to present their solutions to a broad range of senior stakeholders.

Applications close on 13 January 2025. For more information and to view the programme’s use cases, please visit https://www.fintechscotland.com/what-we-do/financial-regulation-innovation-lab/financial-crime/

Nicola Anderson, CEO at FinTech Scotland said:

“FRIL is all about the power of collaboration, bringing together diverse expertise to deliver better outcomes for all.  By partnering with other UK regions, we are strengthening the UK’s position as a leader in financial innovation, connecting the best minds and resources to address some of the industry’s toughest challenges.”

Hilary Smyth-Allen, Executive Director SuperTech:

“Joining this latest thematic call with FRIL, we are building on the strong base of cross-regional collaboration of innovation endeavour.  As the partnership expands, the undoubted winner is the UK; this time in tackling some of the biggest challenges facing industry and citizens as result of financial crime”

Paul Taylor, Managing Director, BT Business:

“By taking part in FRIL, BT will continue to co-innovate with industry partners on key challenges and priorities in tackling Financial Crime. It will allow us to explore FinTech solutions and harness innovation to ensure our customers and businesses are protected today and prepared for tomorrow.”

Paddy O’Keefe, Public Private Partnerships Virgin Money:

“Virgin Money is committed to tackling financial crime, and technology has a key role to play in effectively achieving that. Following the success of FRIL’s ‘simplifying compliance with AI’ programme, we’re excited to support the new ‘innovation to address financial crime’ programme and look forward to engaging with partners to help combat this important issue.”

Ali Fellows, Head of Compliance & Financial Crime, Dudley Building Society:

“Financial Crime prevention is something I am extremely passionate about, having worked in the financial services industry in this area for over 20 years. We have a huge part to play in this, and collaborative working is fundamental in helping drive the fight and shape the future. I am really looking forward to working with SuperTech WM and Fintech Scotland to see how innovation can help develop solutions to help make it harder for criminals to abuse our society and tackle the harm that financial crime causes.”

Robert McKechnie, Director, Credit Products and Strategic Alliances at Equifax UK, said

“This call aligns seamlessly to Equifax’s commitment to strengthen the financial services’ sector in their responding to criminal activities i.e. Identity and Fraud thus meeting their regulatory requirements. The ability to leverage innovative and emerging applications of technology plays a crucial role in the identification and disruption of financial crime and we are excited to be engaging across the FRIL programme to support the development of these solutions.”

Kwaku Osafo, Head of Economic Crime Prevention & MLRO, Insurance, Pensions & Investments Risk, Lloyds Banking Group said:

“Lloyds Banking Group are delighted to be participating in this unique collaborative programme focused on strengthening cross sector efforts to tackle financial crime and fraud. We are looking forward to engaging with industry, academia and regulatory colleagues to explore and harness cutting edge fintech solutions.”

FRIL is a project funded by the Glasgow City Region Innovation Accelerator programme Led by Innovate UK on behalf of UK Research and Innovation, the pilot Innovation Accelerators programme invested £100m in 26 transformative R&D projects to accelerate the growth of three high-potential innovation clusters – Glasgow City Region, Greater Manchester and West Midlands. This is a new model of R&D decision making that empowers local leaders to harness innovation to drive regional economic growth, help attract private investment and develop future technologies.

20 Companies Selected for Consumer Duty Focussed Innovation Call

We’re delighted to confirm the 20 Fintech companies selected to advance to the next stage of our third Innovation Call launched from our Financial Regulation Innovation Lab in partnership with SuperTech West Midlands.

This innovation challenge focusses the theme of consumer duty which is impacting the whole industry. The call was developed in collaboration with 14 leading industry partners: PwC, Tesco Bank, NatWest, Lloyds Banking Group, Equifax, and Barclays, alongside essential community-focused institutions like Dudley, Advance Credit Union, Secure Trust Banks, BNP Paribas Personal Finance, TSB, Castlemilk Credit Union, Coventry and Warwickshire Reinvestment Trust (CWRT), and Moneyline.

With the new consumer duty regulation, financial services organisations are required to make sure they are providing better outcomes for their customers. This means using all data and technologies available to support new the development of better journey, products, services and much more.

Thanks to this call, fintech firms have a unique occasion to work alongside established industry leaders and world-class academics to develop new thinkings and solutions to enhance customers’ financial well-being.

We are continuing to collaborate with the University of Strathclyde and the University of Glasgow to align the initiative with the latest academic research hence advancing innovation in financial regulation across the UK.

Selected Fintechs

Out of 44 applicants from around the world, 20 innovative companies have been selected after demonstrating their commitment to tackling consumer duty challenges through innovative solutions.

Congratulations to Ask Silver, Creditflow, docStribute, EngageSmarter, Guiide, Hope4U, Haboo, Inicio.ai, Malted AI, MyArk, National Support Network, nestegg, planda, Profylr, Sibstar, TellJo, Truzy, UniVeri, VouchSafe, and The Wisdom Council.

For the next few months, they will gain insights into industry challenges and refine their propositions. The programme will involve industry workshops, mentorship, and opportunities to refine concepts with direct feedback from industry partners.

Some of the most promising Fintechs may also be awarded grants of up to £50,000 to support further development of their ideas.

Programme Launch

The selected fintechs gathered in Glasgow on 5 November at the University of Strathclyde’s Technology and Innovation Centre (TIC) to meet industry partners and start building with all involved parties.

Can Technology Transform and Simplify Regulatory Compliance?

At the recent Financial Regulation Innovation event in Glasgow, part of the FinTech Scotland Festival, hosted by Barclays and FinTech Scotland, experts, industry leaders, and academics discussed how new technologies are reshaping regulatory compliance.

Featured speakers included representatives from Barclays, the FCA, Morgan Stanley, Pinsent Masons, and leading fintech firms such as AmiqusAveniEncompassExizentCorlyticsMalted.Ai and docStribute. , providing diverse perspectives on the practicalities and potential of technology in this area.

AI as a Powerful Tool for Compliance

AI was discussed at length as a transformative tool that has the potential to streamline compliance processes while enhancing precision. However, implementing AI for regulatory purposes requires careful integration, especially within legacy financial systems. Without the right infrastructure, this transformation is challenging. Industry leaders highlighted that good data input is crucial to AI model reliability. As one speaker put it, “You get out what you put in” — a reminder that faulty data can compromise outcomes and increase risk.

Ensuring Privacy and Security in AI Applications

Privacy and security were recurring themes, with experts stressing the importance of keeping private data out of models (favouriting synthetic data) and creating “fail-safe” designs. This approach ensures that if errors occur, they aren’t catastrophic. For example, speakers from innovative tech firms presented privacy-enhancing technologies and zero-knowledge proofs, which allow companies to meet compliance requirements without exposing sensitive data.

Future Horizons: Advanced AI Models and Compliance

Next-generation AI models offer exciting possibilities for compliance by tackling more complex, ambiguous tasks over longer time frames. By expanding AI capabilities, the sector aims to unlock entirely new areas of automation and efficiency. However, this shift also requires that financial services firms cultivate higher levels of AI literacy across teams. According to one academic at the event, we are witnessing the “next wave of compliance innovation, requiring regulatory understanding and technical fluency in parallel.”

Regulatory Approaches: EU AI Act vs. UK Ecosystem Model

A panel discussion touched on the contrast between the EU’s AI Act and the UK’s ecosystem approach to regulation. The EU’s model is characterised by a “top-down” structure, while the UK leans toward a more flexible, “bottom-up” framework. The EU’s structured guidelines provide strict compliance benchmarks, while the UK’s adaptable ecosystem approach supports innovation by allowing firms more flexibility in their compliance methods.

Skills for the Future

As regulation and technology evolve together, the skills needed within compliance and risk teams will also change. Smaller, targeted language models are becoming popular for specialised tasks, complementing larger models. These smaller models allow for streamlined implementation and provide focused insights tailored to specific regulatory needs. In the coming years, the industry will likely see growing demand for professionals who can blend regulatory knowledge with AI and data literacy.