Promoting Fairness and Exploring Algorithmic Discrimination in Financial Decision Making Through Explainable Artificial Intelligence
In this white paper a comprehensive toolbox is developed, grounded in an ethical “rights to
explanation” framework, deploying state-of-the-art machine learning/artificial intelligence models,
through the lens of explainability.
Harnessing these explainable artificial intelligence algorithms within the toolbox, we propose implementing an ensemble of model-agnostic techniques, to improve fairness in financial decision making, with a particular focus on US home mortgage loan applications with a granular public dataset.
We also highlight variability in these techniques, imposing various pragmatic scenarios that explore real-world decision making, alongside equality of opportunity and equality of outcome conditions. We highlight potential pitfalls, nuances, and possible innovations in applying these techniques, while providing the ability to simultaneously assess the impact of any specific variable in decision making, and a model’s performance in such decision making, with established machine learning criteria.
Furthermore, we showcase the trade-off between fairness and model performance optimization with a protected characteristic (age) that might form the basis of plausibly discriminatory practices in such a context. Our study aims to be in the spirit of Agarwal, Muckley, & Neelakantan (2023), Kelley, Ovchinnikov, Hardoon, & Heinrich, (2022), Kozodoi, Jacob, & Lessmann (2022), and Kim & Routledge (2022), among others. We lastly identify areas for future research.
Fairness and Discrimination in Lending Decisions: Multiple Protected Characteristics Analysis
We build upon the comprehensive toolbox developed in Jain, Bowden and Cummins
(2024), extending its applicability to multiple protected characteristics.
We explore a way in which several characteristics can be simultaneously considered for multi-dimensional fairness promotion and potential mitigation of plausibly discriminatory practices. In the spirit of Jain, Bowden and Cummins (2024), once again we do this with a particular focus on US home
mortgage loan applications with a granular public dataset.
Finally, we address a prior deficiency, namely a worse overall model accuracy/performance as measured by Area Under the Curve (AUC). The improved AUC can be attributed to a better True Positive Rate of correctly classified loan acceptances, which is achieved with the aid of hyperparameter tuning.
Specifically, we use Stratified K-Fold Cross-Validation combined with overfitting- robust hyperparameter tuning facilitated with the aid of a Grid Search. These were discussed but not explicitly implemented in the use case of Jain, Bowden and Cummins (2024). We document that even a narrow set and range of hyperparameters (mitigating the computational cost of employing the Grid Search) is sufficient to elicit these improvements.
Lastly, we provide recommendations on the implications of our results including where a
human-in-the-loop
Enhancing Financial Crime Detection By Implementing End-to-end AI Frameworks
Economic crime, encompassing money laundering, fraud, scams, and various other
illegal financial activities, continues to evolve with the emergence of sophisticated Artificial
Intelligence (AI) technologies.
This white paper explores the dual-edged nature of AI in the financial sector. While AI tools are increasingly being exploited by criminals to commit financial crimes, they also hold the key to more robust and effective detection and prevention strategies.
This paper delves into the array of AI techniques currently leveraged by malicious criminals, including deepfake technologies, phishing and spear phishing, automated social engineering, credential stuffing, synthetic identity fraud and others.
Furthermore, it provides a comprehensive analysis of AI techniques capable of countering
these threats. Key focus areas include Neural Networks for unusual patterns and behaviours,
gradient boosting algorithms for risk assessment, reinforcement learning for optimisation of
decision making, Markov chains for temporal patterns and anomalies over time, Naïve Bayes
for real-time classification and decision trees for interpretable detection.
The culmination of this paper is the presentation of a state-of-the-art end-to-end AI-driven solution that integrates AI technology to offer a holistic and dynamically adaptable approach to financial crime detection and prevention. By implementing this framework, financial institutions can significantly enhance their capabilities to identify, mitigate, and prevent financial crimes, ensuring a more secure financial ecosystem.
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:
- Lauren Cassells, Research and Innovation Programme Manager (lauren.cassells@fintechscotland.com)
- Gemma Milne, Research Associate, University of Glasgow (gemma.milne@glasgow.ac.uk)
Amiqus Strengthens Leadership in AML Expertise
Scottish fintech Amiqus has just appointed Graham MacKenzie, an expert in Anti- Money Laundering (AML), as its Director of AML & Financial Crime Risk. Graham brings with him over a decade of hands-on experience in AML and financial crime regulation. His career includes roles as Chair of the UK AML Supervisors Forum, member of the Legal Sector Affinity Group (LSAG), and Head of AML at the Law Society of Scotland.
Enhancing AML Capabilities in a Rapidly Changing Sector
With an increase in regulatory demands and the increasing need for firms to proactively manage AML risks, Amiqus is doubling down on its investment in AML solutions. Graham’s appointment is more than a leadership shift, it marks the next phase in Amiqus’ strategy to scale its AML platform for high-volume financial services and wealth management clients.
As part of this evolution, Amiqus is launching a new AML consulting service. This capability will enhance its existing offerings by providing clients with bespoke content, premium support, and access to regulatory guidance, independent audits, and horizon scanning for upcoming regulatory changes.
Looking Ahead
Amiqus is shaping the future of AML services and with Graham, the company will lead the charge in equipping regulated firms with the tools, knowledge, and support they need to navigate an increasingly challenging regulatory environment.
Callum Murray, CEO of Amiqus, commented:
“We’ve committed to scaling the impact Amiqus has by 10x over the next few years. To do that it’s critically important we’re able to attract the very best people to join us across a wide variety of roles.”
I’ve known and respected Graham for a number of years in his previous role and I’m excited for us to put our plans to work, supporting our teams, clients and delivering on the potential we have to fundamentally change the way people are able to reusably access regulated products and services online.”
Graham MacKenzie commented:
“After eight incredible years setting up and running the AML function at the Law Society of Scotland, I have gotten to know the team at Amiqus really well. I’ve always been impressed not only by the quality of their product and solutions but by their overall mission and objectives – growing ethically, sustainably and purposefully, using business as a force for good and making access to legal and other professional services simpler for everyone.”
“When making the decision to move on from the Society, it was important to me to know these are the principles which continue to guide Callum and everyone whoworks at Amiqus.”
“As money laundering and other economic crime risks become ever more complex, and the regulatory landscape expands to keep pace, it is clear to me that using technology you can trust is not only a competitive advantage – it has increasingly become an imperative. “
“As an ex-regulator, I'm acutely aware of the pressures all professional firms face in the current environment. There is however, a huge amount of untapped potential to use technology to help firms in this space and I’m looking forward to using my experience and expertise to support Amiqus and their clients unlock this opportunity, and with wider AML/economic crime compliance requirements.”
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