SmartSearch launches new weapon in fight against global money laundering

Leading UK anti-money laundering specialist SmartSearch has launched a new weapon in the ongoing fight against dirty cash being cleaned around the world through activity such as buying property.

Organised crime gangs and fraudsters are now thought to be responsible for up to $2 trillion a year in money laundering, which is being enabled due to a lack of basic ID checks and document verification, according to SmartSearch.

In response the multi-award winning RegTech 100 firm has now launched SmartDoc, the most advanced document verification system on the market, using a combination of cutting-edge facial ID technology and a level of expert analysis at the same level as border security officials.

John Dobson, SmartSearch CEO, said SmartDoc would not only help businesses in the property, legal and financial service sectors prevent fraud, but also help them remain compliant with global regulations which would result in hefty fines and even prosecution if breached.

He said: “We have built a reputation over the past ten years for our market-leading digital verification solution, which is by far the most effective way to carry out anti-money laundering (AML) and Know Your Customer (KYC) checks.

“But we have launched SmartDoc to run alongside that as another weapon in the armoury for those businesses which feel the need to carry out document verification as part of their customer due diligence.

“The new SmartDoc solution incorporates facial recognition to identify forged ID documents which include photographs, such as passports, driving licences, work permits amongst others.

“SmartDoc will ensure regulated businesses can securely authenticate customer identities, preventing fraud and allowing them to remain compliant with AML legislation.

“While we would always advise customers that electronic verification is the quickest and most reliable way to perform KYC and AML checks, a document checking solution is a key tool due to the vast increase in attempted fraud as a result of the global pandemic.

“The lack of face-to-face interactions caused by lockdown opened a window for criminals to attempt to deceive, and despite restrictions being relaxed, this wave of fraud has not stopped.

“But businesses need to be aware that they are responsible for ensuring they comply with AML regulations and could face severe fines for allowing this activity to go on unchecked.”

The new feature has been developed in part in response to feedback from SmartSearch clients and, by combining leading document authentication technology and the latest biometric verification and liveness detection techniques, SmartDoc provides an accurate picture of the customer, which removes the need for face-to-face interaction.

Not only does the technology confirm whether a document is genuine and unaltered, but that it also belongs to the person presenting it, providing an additional layer of security to identity checks.

It then provides a pass-fail result and also screens the customer against politically exposed persons (PEP) and sanctions lists.

The SmartDoc service combines machine-learning interrogation and an optical character recognition algorithmic check on the ID document machine readable zone, verifying whether the document is genuine and unaltered, with a full data integration to identify document tampering.

Where necessary, it also uses visual scrutiny by a border security trained ID document expert, who will examine every aspect to check security features found in genuine documents, as well as key indicators of potential forgery.

Inclusion In Credit set to share knowledge and best practice

CCR and Arvato Financial Solutions are set to carry out in-depth research and discussion into the reality of inclusion in the credit, collections, and enforcement sector, and are looking for a diverse Oversight Board of industry professionals to oversee this work.

Society has taken significant steps in terms of its acceptance of people of all gender, sexuality, disability, colour, and creed, but, as has been highlighted by several social movements over the past couple of years, there is still some way to go. Likewise, in the credit, collections, and enforcement industry, there are a range of experiences as different individuals face different challenges.

However, there has been relatively little work done to understand the perspectives and needs of diverse communities in the industry, and, at this time of unparalleled social change, CCR intends to change this by carrying out a major piece of work, including: a Research Project, a Round-Table Debate, and a series of Articles from new voices.

Stephen Kiely, editor of CCRMagazine, said: “With pressure coming from the Financial Conduct Authority and the continued economic fall-out from Covid – especially from a new cohort of debtors who have never even been in arrears before – the industry needs to show that it is dealing in a responsible fashion for everyone, and it needs its customer to understand that this is the case so they are comfortable and confident in engaging.

“We hope this project will play a major part in this important effort, by sharing knowledge and best practice, so if you would be interested in guiding this work, please put your name forward.”

  • To put your name forward to be part of the Inclusion In Credit 2022 Oversight Board, please email stephen@ccrmagazine.co.uk.

HighRadius Named to 2021 Forbes Cloud 100 List for the Second Straight Year

HighRadius, the Artificial Intelligence-powered Order to Cash and Treasury Management software leader, has been named to the Forbes 2021 Cloud 100, the definitive ranking of the top 100 private cloud companies in the world, published by Forbes in partnership with Bessemer Venture Partners and Salesforce Ventures. This marks the second year in a row that HighRadius has made it to the prestigious list, based on an evaluation process across four factors: market leadership (35%), estimated valuation (30%), operating metrics (20%), and people & culture (15%).

HighRadius Continues its Strong Momentum and Growth

  • Over $2.2 trillion B2B transactions were processed in 2020 on the HighRadius AI-powered Integrated Receivables Platform. This is roughly the GDP of France, and the volume grew by 74% compared to the prior year.
  • Trusted by 600+ clients with users across 92+ countries. HighRadius clients include 200+ Forbes Global 2000 companies, including eight of the ten largest consumer goods companies in the world, along with four of the five most successful chemical manufacturers, four of the seven largest industrial manufacturers, and four of the five largest food and beverage companies.
  • Raised a Series C fundraise of $300 million in March 2021, tripling valuation to $3.1 billion in a year.
  • Recorded 47% growth in Contracted ARR (Annual Recurring Revenue), compared to the previous year. In fact, HighRadius witnessed a triple-digit growth of 143%, in Europe, since the start of the pandemic (January 2020).
  • Named a Leader (extreme top-right position) twice in a row in the IDC MarketScape for Accounts Receivable Software (Enterprise and Mid-Market editions)

Comments on HighRadius and the Forbes Cloud 100

“The companies of the Cloud 100 list represent the best and brightest emerging companies in the cloud sector,” said Alex Konrad, senior editor at Forbes. “Every year, it gets more difficult to make this list—meaning even more elite company for those who do. Congratulations to each of the 2021 Cloud 100 honorees and to our 20 Rising Stars up-and-comers poised to join their ranks.”

“Being named to the Forbes Cloud 100 for the second straight year is a confirmation that our commitment to finance digital transformation is resonating with customers,” said Sashi Narahari, Founder and CEO of HighRadius. “We have always been focused on the vision of ‘building a long-term business that can outlast all of us,’ which means staying focused on product innovation and customer success. I would like to thank all 2500+ HighRadians, our customers, partners, and investors who helped us reach this milestone.”

“The private cloud ecosystem continues to see historic rates of digital transformation,” said Byron Deeter, partner at Bessemer Venture Partners. “Private cloud valuations are getting bigger as the market’s appetite for cloud continues to grow. These founders represent the absolute best in cloud computing today, and they appear likely to follow in the footsteps of our esteemed Cloud 100 alumni. Congratulations to these cloud leaders!”

“How we work has undergone a paradigm shift and businesses of all shapes and sizes are reimagining the tools that are needed to ensure working from anywhere is a sustainable, long-lasting solution,” said Alex Kayyal, Managing Partner, Salesforce Ventures. “The last 18 months have made digital transformation an urgent imperative and the cloud has never been more pivotal in powering our new digital economy. The companies on this list represent the leaders and businesses shaping the future of the cloud ecosystem and we are excited to partner with Bessemer Venture Partners and Forbes to honor these trailblazers of the industry.”

SmartSearch calls on UK firms to scrap manual ID checks

Leading UK RegTech specialist SmartSearch has launched a new Electronic Verification Uncovered campaign, to raise awareness of the dangers of relying on outdated methods of identity verification for regulated businesses.

The campaign is part of the SmartSearch Index report which is being published to highlight the ongoing threat of money laundering in the UK.

New research* commissioned by the West-Yorkshire based AML solution provider, has found more than a third (34%) of regulated businesses across the financial services, legal and property sectors, still make manual checks when onboarding new customers.

In fact, the research highlighted that in the legal sector specifically manual methods of verification are still preferred by as much as 42% of the firms surveyed. Whereas a third (33%) of financial services, banks and estate agents confirmed they relied on manual checks.

The research, carried out among 500 UK regulated businesses in June, covered a range of topics related to how firms carry out their due diligence obligations. It found that almost one in ten (8.5%) firms in the property agency sector said they do not verify customer ID at all.

In addition, 10% of all firms in the survey said they carry out no checks on business customers with only 70% saying they check financial records as part of the business customer onboarding process – this dropped to 60% in the legal sector.

John Dobson, CEO at SmartSearch, which now operates in the US and the EU, said some of the findings were concerning as hard documents are so vulnerable to being forged.

He said: “It’s really important for regulated businesses to realise that when it comes to secure methods of customer ID verification, documents are high risk and should be at least supplemented with reliable low risk electronic verification.

“This is not only because of the increase in money laundering and financial crime we’ve seen since the start of the pandemic, but also the increasing cost of manually complying with regulations.

“Businesses need to make due diligence and Know Your Customer (KYC) obligations more efficient in terms of speed and cost, as well as remaining secure and accurate. That is not possible by relying on checking passports, driving licences and council tax bills.

“So, we asked businesses why they are still using manual methods of verification and a third said they felt hard copy documents gave them the reassurance that the customer was genuine.

“It’s that kind of belief that we are looking to overturn with our campaign, because increasingly when you’re inviting a customer to send copies of hard documents for verification, you’re actually inviting fraud in through the front door.”

Issues of compliance appear to be behind the decision by those firms to still use manual methods of verification, with a quarter overall (24%) saying it meets AML obligations and a further 30% claiming it’s the only way to guarantee a person’s identity.

However, Dobson is keen to point out that the use of electronic verification has been endorsed in UK law and is much more reliable and accurate.

He said: “When it comes to compliance, regulated businesses can be assured that electronic verification is approved in law. As part of our EU exit, changes to the Money Laundering and Terrorist Financing Regulations 2020 clarifies its support for the increased use of electronic verification.

“Moving away from manual ID checks to electronic verification, will provide regulated firms and their leaders with the confidence that the door is shut against the threat of fraud and money laundering.”

SmartSearch achieves record H1

Leading anti-money laundering specialist SmartSearch has achieved its best ever first half year results in 2021, following a surge in demand for its online ID check and due diligence platform.

The multi-award winning RegTech specialist, based in Ilkley, West Yorkshire recorded 27% in business growth and an increase in users from 45,000 to 53,000. In addition, the firm has seen 21% expansion in its team in the first half of the year, increasing from 135 in January to 164 in June.

After the best year in SmartSearch’s history last year, 2021 has started on a record-breaking pace. The record results in 2021 are as a result of SmartSearch’s industry-leading anti-money laundering product becoming even more essential for regulated businesses.

Across industries, there have been increasing fraud and money-laundering attempts since the outbreak of the pandemic in March 2020. The global crisis opened a window for attempted fraud as lockdown caused face-to-face interactions to become scarce, and criminals used this opportunity to digitally alter documents.

These attempts to deceive are not just restricted to the UK and SmartSearch began offering its market-leading services internationally last year. The AML specialist opened an office in the USA in July last year, and in May 2021 expanded into the Netherlands.

John Dobson, CEO at SmartSearch, which now operates in the UK, US and the EU, said the results were a reward for the hard work of the SmartSearch team.

He said: “We have been continually innovating in the past year to stay ahead of the competition. The market is getting more crowded, but none of the other entrants to the sector offer the breadth, or efficiency of our product.

“The pandemic certainly has attracted the attention of those looking to attempt fraud, and our product has never been more critical to prevent it. Even with lockdown restrictions easing, some businesses are still operating remotely when on-boarding clients, and our system provides a quick and easy method to accurately identify customers.

“Despite the rapid recruitment achieved already, we are still looking to expand our team due to the growth we’ve achieved in the first-six months of the year. We are recruiting for a range of roles, including developers, sales staff and customer service professionals.

“We recently celebrated our tenth-year in operation, and the business continues to go from strength-to-strength. Each year has brought its own challenges, perhaps none as tough as last year, but we are proud to be on course for another record-breaking year in 2021.”

SmartSearch’s industry leading technology can screen new and existing clients without the need to meet in person. With just a few details, name, date of birth and address, the electronic verification technology can identify legitimate clients in just two-seconds.

Webio launches Propensity Studio, the Game Changer in Digital Debt Collections

New AI-powered credit and collections offering from Webio optimises customer engagement using AI and automation and enables companies to manage debt collection conversations like never before.

  • Webio announces its latest product Propensity Studio, which leverages the power of artificial intelligence (AI) to predict customer conversation outcomes.
  • The first of its kind in credit and collections, bringing actionable conversational AI to the industry.
  • Webio is on a mission to rebalance the credit, collections and payment ego-system by reimaging the way companies engage and converse with their in-debt and vulnerable customers
  • Webio delivers credit, collections and payments customer engagement using Conversational AI to make difficult payment conversations easy.

Description

Webio, a leader in Conversational AI and customer engagement orchestration in the credit, collections, and payments industry has launched Propensity Studio, the company’s latest digital debt collection offering.

Propensity Studio leverages Webio’s credit and collections expertise and conversational AI platform to enhance how businesses engage with their customers by predicting individual business outcomes throughout their messaging conversations. Designing fully personalised journeys for all customer types, delivering the right message and level of agent resource at the right time.

Customers have moved to chat, and messaging and companies have had to follow suit shifting their customer engagement to digital channels like SMS, Webchat, WhatsApp, RCS, Messenger, etc. Customers now have an expectation of instant interaction with their companies, whether that is checking on a delivery or discussing their finances.

However, it is a challenge engaging with customers and managing the nuances of each individual customer’s personal circumstances especially for digital conversations at scale. Having the right conversation at the right time in a fair, empathetic, and compliant manner is a need that Webio team are addressing with the development of this AI credit and collections solution. Working hand in hand with clients to develop, this custom-built AI engine is transforming how credit and collections teams will interact with customers.

The first of its kind in credit and collections, Propensity Studio is designed to optimise customer engagement using AI and automation and enable companies to manage digital debt collection conversations like never before.

Webio’s AI Propensity Studio analyses the words, phrases and language of conversations enabling companies to better understand the needs and requirements of their customers in real-time. For example, customers experiencing personal challenges in their lives can be identified more easily and thus get the support they need.

Propensity Studio enables collection organisations and teams to move beyond the traditional customer interaction by:

  • Guiding customer conversations using Natural Language Understanding, incorporating intents, and sentiment analysis, Webio’s Propensity Studio interprets customer’s language, response behaviours and previous conversational history to determine how best to manage each interaction.
  • Working with Webio automated chatbots, or in conjunction with live agents, Propensity Studio identifies a companies specific business outcome within a few utterances a real-time propensity score that identifies how likely a business outcome is. This score can then be used to move the conversation to the next best step. This scoring mechanism allows efficient, low-cost management of the flow and content of an unlimited volume of customer conversations.
  • By predicting what the conversation outcome is going to be, customer journeys can be more fully automated. This reduces the amount of agent resource needed to manage conversations and agents work on the conversations where their talents are really needed. Propensities used in conjunction with workflow rules gets the balance right between automation and live agent engagement.
  • Webio Conversational AI is designed to work empathetically with the end customer’s best interest in mind. Identifying vulnerable customers at any stage and engaging with them in a responsible manner.

Commenting on the launch, Webio CEO Cormac O’Neill says, “Credit and Collections are one of the most challenging customer service environments in the world. It’s an environment whereby having the right conversation can make such a difference in people’s lives. In developing our conversational AI, we have put the needs of indebted customers and our clients front and centre. In so doing our Propensity Studio will not only make a substantial difference to the operational efficiency of businesses but also reshape how customers and companies relate to one another in a new powerful way.”

There has been a lot of hype surrounding AI recently, but the reality is that delivering effective AI that makes a meaningful difference is a challenge. I’m thrilled that Team Webio has met this challenge and I am excited to see the impact that Propensity Studio will have as we continue on our mission of rebalancing the credit and collections eco-system.”

Key Benefits:

  • Effectively manageall customers based on their specific circumstances, whatever they may be.
  • Use Natural Language Understanding to interpret customer’s language, response behaviours and previous conversational history to determine how best to manage each interaction.
  • Manage highly personalised designed conversationsto get the balance right between automation and live agent engagement.
  • Optimising engagementto manage vulnerability.
  • Automate customer journeysmore and even better than you ever thought possible, simply because you know what the likely conversation outcome is going to be.
  • Allows efficient, low-cost managementof the flow and content of unlimited volumes of customer conversations.

SmartSearch calls on UK businesses to work with AMLA

Leading UK RegTech specialist SmartSearch has warned the UK could be left behind in the fight against money laundering and financial fraud, if it fails to coordinate with the new agency being formed by the EU.

It has emerged that the European Commission will launch the Anti-Money Laundering Authority (AMLA) as part of a raft of measures contained in its action plan, set to be revealed on July 20.

The AMLA is a dedicated agency working independently of member states’ national authorities, giving it much greater power to identify and act upon significant money laundering threats.

It will also have new powers to fine businesses in breach of regulations up to ten per cent of turnover, and it will be looking at risks from non-EU countries such as the UK.

John Dobson, CEO at SmartSearch which operates both in the UK and the EU, said: “The formation of a dedicated resource to tackle the growing problem of money laundering, primarily through sectors such as the property market, is a positive step by the EU.

“Since the outbreak of the global pandemic we’ve seen organised criminal gangs in the UK taking advantage by exploiting loopholes in AML processes and using increasingly more sophisticated forged ID documents to get their dirty money through the laundering process.”

As part of the UK Budget announcement in March chancellor Rishi Sunak announced the formation of a new HMRC taskforce to tackle tax evasion and fraud, which is set to employ 1,000 extra investigators.

Dobson says the task force needs to work alongside agencies in other countries and make use of the latest technology to identify the source of the most significant money laundering threats.

He adds: “Of course, this is a global issue so it’s vital that the UK coordinates its response with the EU and other nations, as organised crime gangs won’t be concerned about political borders.

“Obviously as we are no longer part of the EU, this new authority will have no jurisdiction in the UK, but in order to be able to fight the threat of money laundering here in the UK most effectively, it’s vital that we coordinate and cooperate with the AMLA, otherwise risk getting left behind.”

SmartSearch warns against rushing AML to beat SDLT

Leading UK RegTech specialist SmartSearch has warned against the dangers of rushing through anti-money laundering checks, in a bid to beat the upcoming stamp duty holiday deadline at the end of June.

Thousands of homebuyers are expected to benefit from the temporary lifting of Stamp Duty Land Tax (SDLT) for properties worth up to £500,000 in England and Northern Ireland, following the decision to extend the holiday from March.

However, as the deadline gets ever closer there are concerns that mortgage applications and contracts may be rushed through, providing opportunities for criminals and fraudsters to take advantage of a system under pressure.

Martin Cheek, managing director at West Yorkshire-based SmartSearch, said there had been increasing levels of fraud and money laundering attempts since the outbreak of coronavirus, as criminals can easily bypass manual security checks.

He said: “In a busy market as we have today, which is driven by the rush to beat the stamp duty holiday, it’s a sad fact that criminals and their enabling agents, will look to exploit the opportunity.

“Property transactions remain the number one target for money laundering and with the volume currently going through the system there is a danger that some AML checks and procedures may be rushed through.

“But in a way the bigger danger is from agents and legal firms still using manual methods of verification for anti-money laundering processes. Document forgery is a major industry with highly sophisticated products available on the black market.

“It’s almost impossible for even the most experienced broker or agent to tell the difference. If they’re under time pressure, or just seeing a passport image copied into an email, there is a real danger criminal applications will get through unchecked.”

According to Cheek, regulated businesses operating in the property market should be looking to switch to electronic verification as a secure, fast and accurate method of onboarding new customers and remaining compliant with Financial Conduct Authority (FCA) regulations.

He adds: “Financial services firms who are unwittingly processing applications from criminals will be held responsible by the FCA so it’s clearly in their interest to do everything they can to prevent them even getting through.

“The most effective way of doing that is by switching to electronic verification for Know Your Customer (KYC) procedures. With the technology available today it takes two seconds to carry out an individual search, across multiple global data bases, with just a name, address and date of birth.

“Manually checking hard copy documents is no longer necessary, or secure. The switch to digital is long overdue for many businesses who would not only save themselves time and money, but ensure criminals are kept out of the system.”

AML and identity checks: Lessons learned from the NatWest case

NatWest’s landmark money-laundering case has dealt a huge blow to consumer trust in online banking; an industry that more than three quarters (76%) of UK consumers already admit they don’t fully trust, according to research from anti-money laundering specialists, SmartSearch.

The ongoing lawsuit being faced by the high street bank has put others on high alert to the threats and scale of money laundering in the UK, but experts warn this case is the tip of the iceberg when it comes to financial crime in the UK.

So, what can businesses learn from NatWest to avoid the same costly pitfalls? John Dobson, CEO at SmartSearch, shares his expert insight:

Customer trust is shaken

Among the high street banks there really are no two ways about it, your customers must trust that their money is safe with you. Never has this been more prevalent either, with the pandemic forcing many into online banking after the closure of more than 200 branches around the country last year.

With NatWest now facing criminal prosecution after the Financial Conduct Authority (FCA) accused them of failing to appropriately scrutinise numerous suspicious cash payments, this scandal has not only damaged the bank’s reputation but has also impacted consumer trust across the industry.

We know from our research that trust is paramount, so it’s more important now than ever that businesses do everything possible to instil trust among their customer base.

Better electronic identity verification

This isn’t the first time we’ve seen a case of this scale in recent years. Australia’s Commonwealth Bank fell into similar difficulties in 2018 and ended up paying £400 million in fines as a result of failing to adhere to the strict AML regulations.

Even in pre-pandemic times, AML procedures and regulations would frequently change and update to ensure they were as robust as possible, which unfortunately makes way for human error. Over the past year, the use of electronic verification has accelerated, as has the need for more rigorous online security checks.

Developing the right procedure before implementing it is key. By adopting a watertight, multi-layered identity check process, you will eliminate the chances of fraud and ensure any suspicious activity is flagged.

Combine the right technology with robust training

Utilising this kind of system whilst ensuring all staff are kept up to speed on AML law and policy will go a long way to preventing any shortfalls in the process, which will ultimately safeguard against failings.

At SmartSearch we have developed an innovative TripleCheck system, requiring all customers to complete a three stage ID check, including documentation checks, facial recognition and digital fraud and data referencing checks. This approach makes it easy for businesses to identify and eliminate fraudulent activity, helping them to stay AML compliant at all times to avoid sanctions.

To support businesses which are thinking of strengthening their current AML framework with electronic identity verification, John shares the key steps to take:

  1. Given how easy it is to create forged copies of hard documents, it’s vital to implement a framework that requires no more than a name, address and date of birth to carry out a full, global search to verify the customer’s ID.
  2. When looking at online solutions, a single platform with multiple database searches is more streamlined and effective than having to check with multiple platforms, such as Equifax, Experian, then another separately.
  3. Check how the business stores customer details. Not all solutions automatically update the database when changes occur, such there are updated PEP lists and so implementing a system that is aligned to make these changes makes the process more fool proof.
  4. You don’t necessarily have to invest huge amounts in new IT infrastructure to submit and receive data. The quickest and simplest access for users is through the browser on your company laptops and desktops, which are safeguarded by heightened security and protection.
  5. It’s vital to check how easy it is for anybody in the company to use. The most advanced technology should be easily accessible for people who need to use it day-in day-out, and not the just IT dept, to avoid any confusion or mistakes when handling personal information.
  6. Ensure the ID verification system you implement includes FCA compliant data records automatically. If your business is required to provide an audit, having a system designed to incorporate detailed records which are fully compliant will save you time.
  7. Using technology such as facial recognition will further enhance the level of certainty when checking an ID. If integrated with global database searches and document verification you can be sure you have a watertight system that meets all regulations.

SmartSearch warns against risk of GDPR breaches

Leading anti-money laundering specialist SmartSearch has warned many businesses may be at risk of being in breach of GDPR rules, due to a lack of secure data hosting.

The end of May marked the third anniversary of GDPR becoming law in the UK, yet according to the RegTech specialist, regulated businesses in the housing chain risk non-compliance if they rely on manual customer records.

John Dobson, CEO at West Yorkshire-based SmartSearch said that even three years after the law was introduced, a lot of firms do not have procedures in place to protect customer details, which has been exacerbated with the disruption caused by the coronavirus outbreak.

In response to the concern, SmartSearch has enhanced its data hosting capability which updates customer details automatically when something changes, both increasing due diligence and data security.

Dobson adds: “Customer data hosting is something that can be overlooked, or businesses think the processes they have in place are good enough. But the fact is, even three years after the introduction of GDPR, a lot of firms still have manual records in the office, which poses a genuine GDPR risk.

“If you have a digital platform in place to carry out ID verification for AML purposes when onboarding new customers, it’s crucial that the data is hosted so that it updates automatically. And if there is a knock on the door from the auditor, a fully hosted system will make it quick and easy to pull a report which has everything on it necessary for compliance.

“Once the customer inputs their client data, they don’t need to do anything with it from an AML perspective, which enables them to forget about it and get on with the job of running their business.”