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Abstract
The potential applications of emerging technologies to anti-money laundering (AML) compliance programmes present a variety of benefits and challenges to financial institutions. Recently, technologies such as machine learning and natural language processing, biometrics, geolocation, and blockchain and smart contracts have shown tremendous potential to bolster the AML compliance efforts of financial institutions. However, the use of these technologies in AML compliance programmes of financial institutions present a number of challenges. This paper discusses these emerging technologies, the potential applications of such technologies to AML compliance programmes of financial institutions, and the associated benefits and challenges of these potential applications. This discussion is particularly important given increased regulatory scrutiny of financial institutions and their AML efforts in recent years.
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Author's Biography
Barrie Vanbrackle is a partner in the Washington, DC office of Latham & Watkins. Barrie helps merchants, payment processors and FinTech vendors navigate key areas at the intersection of technology and finance. She regularly guides clients on transactions involving payment systems participants, including large merchants and financial technology companies, with respect to payment acceptance, payment issuance, co-brand agreements, payment card industry data security issues and payment regulatory matters. She also has significant experience advising corporate and private equity clients within the context of mergers and acquisitions and other FinTech investments. Barrie holds a BA from Johns Hopkins University and a JD from Washington University in St. Louis.
Parag Patel is a partner in the Washington, DC office of Latham & Watkins. Parag advises financial services companies, financial institutions and FinTechs on transactional and regulatory matters, with a particular focus on emerging payments, innovative technology, consumer and small-business lending, and banking. He has an extensive background in the regulation of money transmitters and other types of money services businesses and has helped dozens of FinTech startups navigate these rules at various stages of their business evolution. Parag holds a BA from the University of Georgia and a JD from the University of California, Berkeley School of Law.
Victor Razon is an associate in the Washington, DC office of Latham & Watkins. Victor advises traditional financial institutions, FinTechs and other companies on a range of regulatory and transactional matters, specifically in the context of emerging payment and lending services. Victor helps clients develop products and services and operate in accordance with applicable law and guidance, including anti-money laundering requirements. During law school, he worked for a variety of federal financial services regulators, including the Securities and Exchange Commission, the Consumer Financial Protection Bureau and the Department of the Treasury. Victor holds a BS from the University of Florida and a JD from the George Washington University Law School.