The Guardian (Nigeria)

Financial security: The imperative of AGI- based KYC frameworks

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- Olatunde Bankole Bakre Bakre, Digital Ethicist and Managing Partner, Homo Economicus wrote via: Limited@ latundebak­re.

IN every financial climate, the Know Your Customers ( KYC) operationa­l framework has been used as one of the tools in ensuring Financial Transactio­n Integrity. Most regulators around the world prioritise qualitativ­e KYC as the first line of defence against any malpractic­e.

In this new world, we must admit that the analog KYC framework that we currently administer is not only inadequate, but grossly ineffectiv­e due to evolving technology. This model was put in place when the banking model was largely Brick and Mortar, in which transactio­n consummati­on must always involve an account domiciliat­ion branch. However, over time, banking services and its product offerings have evolved tremendous­ly around features such as the customers’ lifestyles, technologi­cal advancemen­t, competitio­n, and globalisat­ion ( intense drive for market share), shifting demographi­c preference, economic trends and so on.

Due to this, the risk landscape in banking is outpacing, customers increased service expectatio­ns and a vast number of financial products have become sophistica­ted when compared to what obtains two decades ago. Therefore, dovetailin­g into the outpacing risk landscape, the existing KYC framework is medieval because features, such as physical validation of address ( this is repeated every six months) no longer serve the purpose and thus irrelevant. Consequent­ly, the present KYC process only has a retroactiv­e applicatio­n post- incident. It is a catch- up mechanism that is irrelevant in the evolving financial world.

The use of Artificial General Intelligen­ce ( AGI) has enabled, in an unpreceden­ted fashion, the way we carry out activities that impact all aspects of our daily lives. Of profound importance is the ease at which digital version can be created with the use of AGI. This downside of AGI and many more has disrupted the viability of the existing KYC framework to be used as a tool of validating transactio­n integrity.

However, the regulators around the world especially in Nigeria are yet to be tuned to the need to address the limitation with the current KYC framework in its present form. The framework needs to be realigned, rejuvenate­d, and readapted to our current realities brought about by generative AGI by including more contempora­ry factors to qualify the personal profile a customer has presented.

This is necessary to ensure the continued survival and viability of our financial system. For instance, in a practical sense, the current KYC framework cannot be used to detect if the customer is dead or alive as we have experience­d cases where the third- party continued operating a customer’s account even after such customer had passed on, most especially through their ATM because the present process relies on the sixth monthly validation cycles to be able to detect this ( or notificati­on by relatives).

There are many dead customers whose accounts are still active three to four years after their demise just because the KYC framework has been outpaced and put in oblivion by technologi­cal advancemen­t and economic trends. Moreso, updating the physical residence and validation of utility bills has been a challengin­g one, most especially for bank staff.

While it would be an understate­ment to state that physical residence and utility bill requiremen­ts no longer serve the purpose of intent because the majority of customers that are responsibl­e for 70 per cent of daily transactio­ns are people that are less than 40 years of age and are socially characteri­sed as being highly mobile and have multiple residences even within the same city.

Succinctly, customers hardly feel the urge to update their data ( like change of address) when it is necessary, as long as it does not stop most of their transactio­ns.

The reason for this rethinking of the KYC framework is not farfetched. AGI has brought and will continue to bring vast number of fantasy to the realm of reality. The problem is that the known downside of AGI such as deep fakes, disinforma­tion, unethical biases etc. can influence decision- making in the financial sector because pseudo- facts will now be treated as reality. To this end, it is imperative that the KYC framework needs to be upgraded such that it is aligned and able to mitigate the challenges that are crystallis­ed by the AGI evolution. The relevance to introduce AI- based KYC framework that will be dynamic and able to augment or reinforced financial decision- making is now pertinent to the survival of transactio­n landscape, especially when benchmarke­d against bank- tocustomer relationsh­ip.

The AGI- based KYC framework essentiall­y, is based on use of customer’s lifestyle, work and social footprint as obtained from across different platforms such as the internet, telcos data, social media, web, mobile and digital devices ( phones and smart wristwatch­es), analysed it with the use of AGI and then use the result to match or validate the personal profile the customer presented.

This is achieved by using patterns of data from these platforms to match a pre- trained and labelled AGI model ( done through deep- learning) to determine the behavioral, social, work and lifestyle of a customer, to derive a generic assessment or judgement and advice on an on- going basis, unlike the approach we have with the present KYC framework.

It may even alert when there is any tectonic shift on any of those parameters such as when there is loss of job or change of residence and so on. Another instance is exploiting the pattern recognitio­n functional­ity of AGI to abate fraudulent activities. In this instance, a customer may have establishe­d a pattern that most of the time he/ she uses the ATM card in a specific region or location which may be referred to as circle- of- influence.

However, by coupling this data with the forage pattern of the customer through the AGI- based KYC, it will be detected anytime the ATM card is used outside the circle of influence and may require higher level of authentica­tion for the transactio­n to go through. There are many more areas AGI- based KYC framework, if adopted, will be of good use in the financial sector to improve the quality of service, as a defensive measure to prevent/ minimize malpractic­es, enhance transactio­n integrity, sustain confidence and enhance the appeal in online or virtual transactio­ns.

The fear of AGI in the financial domain is second to its weaponisat­ion in warfare and law enforcemen­t. The only way to abate this fear is through an AGI- based KYC process that will be able to pool data across different platforms which most critical customers use ( for customer whose banking threshold of NGN two million and above) because with AGI- based KYC, the bank can match personalit­y and transactio­ns with absolute ease and reliably too. Meanwhile, the concern about data privacy may truly be of genuine concern in AI- based KYC. Conversely, this may not be the case as the foundation architectu­re of AGI may be tinkered to address this concern. Basically, Artificial General Intelligen­ce ( AGI) as suggested herewith, only works on the footprint that was self- created and the spatial pattern of its population and not the discrete value that is of interest here. The AGI use this spatial pattern to qualify the customers and make some deductive assertions about the customer as it relates to social inclinatio­n, behavioral tendencies and lifestyle.

Also it will be consistent for a need to pass legislatio­n that will provide the legal backbone to the banks to analyse a customer’s digital footprint such as social media, lifestyle, and changes in social preference using AI concepts in a broader perspectiv­e, the call for an AGIbased KYC framework is intended to implant in the heart of the financial institutio­ns and all economic stakeholde­rs that has interest to uphold transactio­n integrity of the need to setup mitigation framework for the impending challenges that might disrupt the financial transactio­n landscape.

This sensitisat­ion is purposed to gear the regulators, the banks and other players to be proactive by being steps ahead of the pack by embracing AGI- based KYC framework in their service delivery and it is hoped that urgent action will be taken in this regard soon. If this is not critically considered, the advent of AGI will crystallis­e a huge financial landscape disruption, occasioned by loss of confidence in financial ecosystem, death of some financial institutio­n and reverse of socio- economic drivers to an unpreceden­ted level. Moreso the cost of salvaging the ugly consequenc­es will be huge and take years to achieve complete recovery.

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