Are computerised profiling tools effective in support of AML procedures as required by MLROs and compliance officers in a banking sector context? An inquiry into determining effectiveness despite ambiguity.

摘要

This dissertation aims to contribute to the emerging field of automated behavioural profiling tools/technology (AMLPT) as applied to anti-money laundering (AML) and fraud detection. We research the effectiveness of the use of profiling technology within the context of compliance Organisations located in large and mediumsized retail and commercial banks within the City of London. The phenomena of profiling and money laundering are quite complex. Subsequently, their study encompasses several academic disciplines: language use, artificial intelligence, categorisation, and the managerial domains of organisational behaviour, networking, and innovation. Using an interpretivist approach, we examine the AMLPT artefact's effectiveness through the use of Rogers' Diffusion of Innovation (Dol) theory, utilising a pluralist methodology that encompasses two case studies for contextual understanding of the domain and survey-based field work. In furthering our understanding of innovation within organisations, we utilise Organisational Effectiveness (OE) theory to provide an analytical framework for the fieldwork and measurement methodology. The proliferation of AMLPT raises a variety of issues arguably more important than market share and technical functionality, particularly such issues as data privacy and the potential for the egregious use of personal or proprietary information (Schwartau 1994; Jennings and Fena 2000; Lyon 2003). Furthermore, what was once perceived as "normal" identity management, data security and data privacy practice may no longer be acceptable in the application of next generation AMLPT in risk-aversive, highly sensitive global financial contexts. Moreover, are the cost and Organisational demands inherent in deploying AMLPT proportionate to the desired result (Bisantz and Ockerman 2002; Vavpotic and Bajec 2009). In understanding the effectiveness of AMLPT, we look beyond the traditional methods of information systems evaluation, and draw on other IS reference disciplines such as IS success and user competence, along with a variety of Organisational effectiveness measures, and their applicability in further defining effectiveness through measures of innovativeness. Critically, we look to examine innovation in an Organisational context, rather than the more traditional domain of individual innovation, the core construct of Rogers' original (1962) work on diffusion.