By Colin Bristow, Customer Advisory Manager at SAS
Forming a significant theme in several organisational technology strategies, AI can augment a gamut of business practices, including compliance. Compliance is a must-do activity, not a nice-to-have. It is essential that companies extract maximum value from compliance processes, reducing the possibility of it being considered a cost centre.
Technological innovation can help to lift some of the compliance burden. The level of technology you can realistically implement depends on how advanced the organisation is to start with. One company’s moonshot could be another’s business as usual. Assessing the starting point is just as important as considering the benefits and end goal.
RegTech, AI and the future of compliance
This is the question that the burgeoning RegTech (regulatory technology) industry is seeking to answer. AI is typically at the forefront. RegTech partly focuses on improving the efficiency and effectiveness of existing processes. As part of that improvement, organizations are using AI, machine learning and robotic process automation (RPA) to smooth the integration and processes between new RegTech solutions, existing legacy compliance solutions and legacy platforms.
Why look to AI for help? Recent regulations, such as GDPR or PSD2, are handed down in the form of large and extremely dense documentation (the UK government’s guidance document for GDPR alone is 201 pages). Identifying the appropriate actions mandated by these lengthy documents requires a great deal of cross-referencing, prior knowledge of historical organisational actions, and knowledge of the relevant organisational systems and processes. What’s more, several regulations attract fines or corrective actions if not applied properly (like the infamous “4% of company turnover” penalty attached to GDPR).
In short, the practical application of regulations currently relies on human interpretation and subsequent deployment of a solution, with heavy penalties for noncompliance. This is where AI can help, reducing the workload involved and improving accuracy. Here are three key examples of how AI can help companies turn compliance into a value-added activity.
1) Reducing the risk of nonconformity
Following the deployment of compliance processes, there is often residual risk. This can be as a result of unforseen gaps in compliance processes, or unexpected occurrences that become apparent when operating at scale.
That’s partly because there are usually a lot of steps and processes to be carried out during the data collation stage of compliance programmes. RPA can help reduce administrative load associated with these processes that include a high degree of repetition – for example, copying data from one system to another. AI can then help process cross-organisational documentation, combining internal and external sources and appropriately matching where necessary.
AI can also help to reduce companies’ risk of noncompliance with, for example, privacy regulations. Furthermore, using AI techniques, organisations can automate transforming and enhancing data. Intelligent automation allows companies to carry out processes with a higher degree of accuracy.
2) Improving process efficiency
Inefficient processes can also hinder compliance. For example, automated systems that detect suspicious transactions for anti-money laundering (AML) processes are sometimes not always as accurate as they could be. A recent report highlighted that 95% of flagged transactions are closed in the first stage of review. Effectively, investigators spend most of their day looking at poor quality cases.
Use of an AI hybrid approach to detection ensures there are fewer, higher quality alerts produced. Furthermore, it is possible to risk-rank cases which are flagged for investigation, speeding up the interaction and relegating lower-risk transactions. Although AI forms an underlying principle across most modern detection systems, maintenance is key to managing effective performance.
AI can also be used to bolster AML and fraud measures more widely. For example, applying AI to techniques such as text mining, anomaly detection and advanced analytics can improve trade finance monitoring. This, in turn, can improve the regularity for document review and consignment checking, improving the validation rates of materials as they cross borders.
3) Keeping up with regulatory changes
Compliance never stands still. Businesses have to contend with a constantly evolving landscape, potentially across several regions. AI can help to optimise the processing of these regulations and the actions they require, helping companies keep up to date. Companies that need to effectively comply with several differing regulations require a wide range of understanding across all parts of the business. The size, complexity and legacy systems of the business can be significant obstacles.
To mitigate this risk, companies can use natural language processing (NLP) to automate aspects of regulatory review, identifying appropriate changes contained in the regulation and then relaying potential impacts to the appropriate departments. For example, AI could help geographically diverse companies determine whether changes in the UK have an impact on their Singapore office.
Humans still needed
It’s important to note at this point that AI and RegTech are not expected to widely replace humans. We are seeing early AI entries in the RegTech space, but they’re primarily helping with lower-hanging fruit and repetitive tasks. AI is primarily enhancing the work humans do, making them more effective in their roles.
AI does not come without some considerations, however. There is a great deal of focus and scrutiny on associated possible bias in AI deployments. Other discussions are exploring the transparency and governance of applications and questions around who owns generated IP. As a result, it’s essential that AI works closely with humans, enhancing activities and balancing an appropriate level of manual oversight.
AI is augmenting compliance practices by providing faster document review, deeper fraud prevention measures and greater contextual insight. It is also reducing noise in high-transaction environments and lightening the documentary burden on staff. From the start of the regulatory review to the end of the compliance process, AI holds part of the overall solution to a more efficient and valuable compliance function.
HOW TO KEEP DIGITAL TRANSFORMATION ON TRACK AFTER THE PANDEMIC
Ashley Coker, CEO and founder, Slate
The global coronavirus health emergency has made it abundantly clear how dependent we are on digital services for business continuity and social cohesion. When physical contact must be minimised, digital businesses are in a better position to rapidly adapt and continue their services and respond to customers’ needs.
This is perhaps why Chancellor, Rishi Sunak, was prompted to delay the introduction of IR35 Off-Payroll working rules to the UK private sector until April 2021, as part of his package of measures to support British businesses through the COVID-19 crisis.
While some businesses expressed relief at the delayed introduction of IR35 rules in the private sector, many financial enterprises had already terminated contracts with IT contractors in preparation for the original deadline, with the risk of digital transformation programmes stalling.
What is IR35?
Inland Revenue legislation 35 (IR35) is a tax law designed to prevent individuals from using intermediaries, such as their own limited company, in order to avoid paying their fair share of tax and national insurance contributions (NICs). By setting up a limited company, some people were able to leave their employment in a bank on a Friday and return to the same job on a Monday as an IT contractor, with no change in their role, duties, or place of employment. HMRC wants to put a stop to this.
However, with an estimated 170,000 contractors working through their own personal service companies, HMRC has not had the resource to address cases individually and decided to put the onus on the organisations that hire contractors.
From April 2021, the responsibility for assessing whether a contractor is genuinely self-employed (outside of IR35) will fall on every medium and large private sector organisation with a turnover of over £10.2 million, a balance sheet of £5.1 million, and more than 50 employees. This means that every contract will have to be reassessed to decide whether an individual’s work falls inside or outside IR35. Contractors must be provided with a Status Determination Statement (SDS) for each contact that they undertake, confirming the organisation’s assessment of their status for IR35 purposes.
How has the financial sector prepared for IR35?
To avoid the time and resource required to scrutinise thousands of contractor contracts, many financial services organisations took a blanket decision which deems that all contractors are working inside IR35. Several prominent organisations have taken this route and terminated all contracts with contractors who bill for their services via limited companies.
Being deemed to be working inside IR35 has the effect of making hiring organisations liable for paying contractors’ income tax and National Insurance contributions at source, as though they were employees, without contractors benefiting from the sick pay and holiday pay benefits of the organisations’ employees. Tax experts have calculated that working inside IR35 will reduce contractors’ incomes by approximately 25 per cent. This makes projects less attractive to IT contractors who might be working on delivering digital change.
How does IR35 affect Digital Transformation?
Prior to the IR35 deadline extension, HSBC, Lloyds bank and Barclays bank were reported to have taken a uniform decision to classify all contractors as working within IR35. It was also reported that Deutsche Bank risked losing 50 out of 53 contractors working in its London-based change management team after taking the decision to cease working with contractors via personal service companies and asking them to join the payroll of a recruitment outsourcing agency used by the bank.
If IT contractors stop working with their financial service industry clients, to avoid falling foul of IR35 after April 2021, this could have a devastating impact on digital transformation projects that depend on the specialist skills of external contractors.
A number of contractors have reported that they plan to seek employment overseas after IR35 comes into force in the private sector, so that they can carry on enjoying the flexibility, job satisfaction and remuneration of working off-payroll. This could result in a brain drain for many sectors, such as banking, which relies heavily on the skills of external IT contractors to deliver digital transformation.
Fast track to digital delivery:
While IR35 could pose serious challenges for digital change programmes in the UK financial services sector after April 2021, some CIOs we have spoken to see the contract renewal phase as an opportunity to clear the decks, refocus and keep their best people on the pitch.
Our experience of providing corporates with highly-skilled software engineers who are born problem-solvers, who work in small, capped teams on a 5 in 50 model, has shown that they are often fundamental to getting stalled digital change programmes back on track. These developers work alongside enterprise IT teams, on a Seed, Scale, Succeed process, bringing fresh coding skills and transforming project thinking into product thinking, with continuous delivery of digital service iterations. They are technology specialists who relish the challenge of working on high profile digital journeys, but who do not wish to work as corporate employees and are therefore hard for financial services organisations to hire.
We now have another twelve months to prepare for IR35. In the meantime, as financial services organisations adapt to the demands of the pandemic, this is the time for small, agile teams of problem-solvers to shine.
IN CONSUMER BIOMETRICS WE TRUST: AUTHENTICATION FOR THE DATA PRIVACY AGE
Jonas Andersson, Head of Standardization at Fingerprints
Data privacy is high on the global agenda. In the wake of data protection policies such as Europe’s GDPR, ensuring the integrity of personal data is an increasingly pertinent subject. This is a governmental and corporate policy reflection of the fact that our lives are moving increasingly online and, with it, our personal data is facing new and increased threats.
For all access to private data or services, we must be authenticated – this is the basis of privacy in the online world. But as PINs and passwords are increasingly viewed as insufficient to tackle this new reality, the world is looking to stronger authentication solutions, such as biometrics.
When implemented in the right way, biometrics will bring multiple benefits. It already enabled consumers to add layers of authentication to personal data previously unsecured in their owned devices – from apps and e-commerce, to our homes and devices. But its potential is phenomenal. Consumer-driven authentication via our phones and tablets is already today by far the largest application of biometrics in the world, with figures in the billions that dwarf government-led identification schemes such as India’s Aadhaar and the FBI database.
Crucially though, it’s a privacy and security measure that consumers have the power and choice to implement. And as third parties, such as financial services, healthcare and enterprise organizations, increasingly accept consumer biometrics authentication for their services, supporting the market’s continued adoption is an important and timely topic. But first, as biometrics creates its own sensitive personal data, there are a few points to clarify and discuss…
Consumers need confidence!
Undeniably, the success of existing applications of consumer biometrics is based on the advantages they offer consumers. Just look at the penetration and use of fingerprint biometrics in smartphones. But the success of future adoption will be determined by how confident consumers continue to feel in new situations. We’re frequently reminded not to use the same password or PIN multiple times, so it’s only natural consumers are beginning to feel concerned of their biometrics integrity as they start to utilize their fingerprint on multiple devices and apps: their phone, tablet, card, USB dongle…
In fact, consumer device authentication utilizes a ‘privacy by design’ approach that inherently protects end-user biometric data with an on-device authentication approach – where biometric data is enrolled, stored and managed all on the same device. The following principles have been fundamental to biometrics’ privacy protection in mobile and are what will enable new benefits for consumers in other personal device-based scenarios:
Translating images to templates
It’s a common misconception that biometric data, such as fingerprints, are stored as images. And in turn, if this image is accessed, the corresponding fingerprint is permanently compromised and unable to be restored or used securely on other applications. You’ll have heard the argument about biometrics: “I can change my password any time, but I only have ten fingerprints; what happens if they’re all hacked?”
In fact, data from a biometric sensor is captured and stored as a template in binary code – or encrypted 0s and 1s. This mathematical representation makes hacking basically pointless as, even if fraudsters could access the template, they can’t do anything with it. Template code cannot be reverse engineered into the original fingerprint image, nor can it be linked to other services and, in turn, other personal data. Moreover, this template is unique to the device it is on, making it impossible to re-use between devices, even if the same fingerprint has been enrolled!
The consumer is in control
This neatly leads on to my next point regarding storage. In consumer authentication use cases, information remains solely on the unique consumer device on which the template was created, remaining physically in control of the user.
Our recent consumer research found 38% were unwilling to share their biometric data but, with this approach, no data needs to be shared with third parties or cloud-based databases as everything is stored, and the authentication process is contained, within a single personal device.
Layers of security
Layering defense mechanisms is standard best practice for a range of security implementations – biometrics is no different. In addition to the transformation of biometric data into an irreversible template, these templates are also later encrypted and further protected by hardware and software both at rest and during the matching process.
The most successful example of a biometrics use case, the smartphone, utilizes the highly secure software isolation of Trusted Execution Environment (TEE) technology for storage and matching of biometric templates on device. The hardware on which it runs is intrinsically secured through its high degree of integration, complexity, miniaturization and specialization.
This approach is also championed by new use cases such as biometric payment cards. Here, the Secure Element (SE) – the chip technology that secures the financial data in your bank card – is utilized to store, process and match biometric information within the confines of the card. This treats biometric templates with the same security as the PIN and other financial data that is stored on our payment cards.
Removing the weakest link
Nothing is ‘un-hackable’, this is the reality of security. With enough time, money and effort, it’s possible to get into anything. A safe, a bank vault. However, attackers take the path of least resistance, and often it’s the end-user that is the ‘weakest link’ in the security chain when it comes to social engineering attacks.
End-users are vulnerable to attacks, such as phishing, where they can be tricked into giving away information such as a PIN or password. With consumer biometrics, the user only presents their biometrics to their personal device and can’t give anything away. This also removes the risks generated by mistakes or complacency, such as creating a password that’s easily guessed.
More authentication = more protection
Biometric authentication can protect a whole host of other sensitive personal data, far more quickly, conveniently and securely than was ever possible with PINs or passwords.
Today however, passwords and PINs remain the most used authentication methods outside of smartphones – something increasingly problematic. The friction created by asking users to create a new password has a significant impact on drop-out rates – especially as new ‘best practice’ guidelines recommend complex requirements such as including numbers, capitals, special characters and length. NIST’s digital identity guidelines outline the importance of usability challenges and stress, fundamentally, “positive user authentication experiences are integral to the success of an organization achieving desired business outcomes.”
6 out of 10 consumers feel they have too many PINs and passwords and worry about forgetting them. Unsurprisingly, 41% also admit to re-using the same PIN code or password across multiple sites, apps and devices. So, not only are PINs and passwords frustrating for consumers, they’re also becoming less secure.
Biometrics can be the authentication silver bullet as it combines security and a convenient UX, with leading fingerprint sensors authenticating in under a second. Its capacity to bring security to devices and processes previously either unsecured, poorly secured, or secured with a poor UX is phenomenal. Mobile is the perfect example of how it has been able to transform a device from being unsecured most of the time, to now only unlocked when in use. And now, just look at how your bank accepts your fingerprint authentication on your phone for access to your account.
With consumer biometrics, its quick and effortless to enroll onto new services and subscriptions. Consumers are happy to authenticate more frequently, because it’s so simple and the action is so intuitive. Plus, you cannot forget your fingerprint…
Consumer biometrics: on the agenda
It’s clear that biometrics is key to many organizations’ plans for privacy and security, but don’t just take our word for it. Many industry and government initiatives are moving quickly.
Europe’s GDPR highlighted biometrics as ‘sensitive personal data’ which clearly needs to be protected in the right way. Meanwhile, the benefits and integrity of consumer device biometric authentication were also recognized by Europe’s financial services directive, PSD2, citing biometrics as a trusted factor under its strong customer authentication (SCA) mandates.
Looking to industry bodies, FIDO Alliance is gaining significant traction in formalizing the quality and security of personal authentication with biometrics. Its work is complementing rising initiatives such as Self Sovereign Identity (SSI) models, whereby individuals or organizations are endeavoring to have sole ownership of digital identities and control how this personal data is shared and used. With an owned, FIDO-certified biometrics-secured device, users can add another authentication layer over stored digital identifiers.
For several years, we’ve also participated in industry body GlobalPlatform’s work to verify and standardize the quality of security protection on TEE. The biometric API extension defines security protections specifically around biometrics and is highly referenced in mobile implementations, and increasingly in new devices such as key fobs and home security devices too. With the dawn of the biometric payment card, we’re also supporting GlobalPlatform to define an SE specification for biometric cards.
The combination of government and industry engagement is setting the scene for so much more to be achieved with consumer authentication using biometrics. Undoubtedly, biometrics’ role in an increasingly data-conscious world has only just begun to take shape, and excitingly, it’s consumers who have the power at their fingertips – quite literally!
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