COMPLIANCE
information with credible sources and consult professionals when needed to ensure accuracy and appropriateness for your specific situation .” 17
2 . Google , Bing , Yahoo ! and other search engines are not only useful but are required .
3 . The absence of source documentation is a serious impediment . Although ChatGPT may provide sources upon request , when it does provide sources , they must still be verified because ChatGPT may provide nonsensical answers . 18
4 . As a training tool , the current version is sadly lacking : The Federal Financial Institutions Examination Council ’ s “ BSA / AML Examination Manual ” 19 remains not only a useful tool but an authoritative source ― even if it is wrong , if it is in the manual , your regulatory interlocutors will be hard-pressed to challenge you .
5 . Criminals will like ChatGPT ’ s simplicity and ease of use . They are not known for checking source documents or looking for citations , so there is no impediment there . But that also means they may get it wrong , which is a great help to those of us in the AML / CTF field .
6 . Even if all of the above tells you nothing you do not already know , we hope you will agree on one thing : Human intervention will be a necessary part of any effective compliance framework for some time to come . Unlike elevator operators , phone operators , parking lot attendants and other jobs requiring mechanistic responses , evaluating risk factors and red flags ; detecting , investigating and analyzing suspicious activity ; as well as advising the business line on the risks of doing what they always want to do ( onboard , maintain , protect and defend the client ) will still be a fundamental part of compliance and require the complex logic , reasoning and intuitive thinking that only humans are capable of , at least for now .
7 . Finally , the AI landscape is changing so quickly that everything we have written about it will be outdated eventually , and some of it by the time this article is published .
Amanda Bini , legal research consultant , Law Office of Ross Delston
Ross Delston , CAMS , independent American attorney and expert witness , Law Office of Ross Delston
The authors wish to acknowledge the assistance provided by Dr . Neha Singh , AI / machine learning , natural language processing and data science expert .
1
Akash Takyar , “ AI Use Cases & Applications Across Major Industries ,” LeewayHertz , https :// www . leewayhertz . com / ai-use-cases-and-applications /
2
“ Dark Web Crimes ,” FindLaw , https :// www . findlaw . com / criminal / criminal-charges / dark-web-crimes . html
3
“‘ Pig Butchering ’ Scams : What They Are and How to Avoid Them ,” FINRA , December 13 , 2022 , https :// www . finra . org / investors / insights / pig-butchering-scams
4
Miles Brundage , Katie Mayer , Tyna Eloundou , et al ., “ Lessons learned on language model safety and misuse ,” OpenAI , March 3 , 2022 , https :// openai . com / research / languagemodel-safety-and-misuse
5
David Nield , “ How ChatGPT and Other LLMs Work ― and Where They Could Go Next ,” Wired , April 30 , 2023 , https :// www . wired . com / story / how-chatgpt-works-largelanguage-model /
6
Sara Merken , “ New York lawyers sanctioned for using fake ChatGPT cases in legal brief ,” Reuters , June 26 , 2023 , https :// www . reuters . com / legal / new-york-lawyerssanctioned-using-fake-chatgpt-cases-legalbrief-2023-06-22 /
7
James Vincent , “ OpenAI sued for defamation after ChatGPT fabricates legal accusations against radio host ,” The Verge , June 9 , 2023 , https :// www . theverge . com / 2023 / 6 / 9 / 23755057 / openai-chatgpt-false-informationdefamation-lawsuit
8
“ Introducing ChatGPT ,” OpenAI , November 30 , 2022 , https :// openai . com / blog / chatgpt
9
This information was obtained directly from ChatGPT . It should be noted that ChatGPT sometimes writes plausiblesounding but incorrect or nonsensical answers . Please view the following source for more information : “ Introducing ChatGPT ,” OpenAI , November 30 , 2022 , https :// openai . com / blog / chatgpt
10
Ibid .
11
Ibid .
12
Jeffrey Dastin , “ Amazon scraps secret AI recruiting tool that showed bias against women ,” Reuters , October 10 , 2018 , https :// www . reuters . com / article / us-amazon-com-jobsautomation-insight-idUSKCN1MK08G
13
This information was obtained directly from ChatGPT . It should be noted that ChatGPT sometimes writes plausiblesounding but incorrect or nonsensical answers . Please view the following source for more information : “ Introducing ChatGPT ,” OpenAI , November 30 , 2022 , https :// openai . com / blog / chatgpt
14
Ibid .
15
“ Section 314 ( b ) Fact Sheet ,” Financial Crimes Enforcement Network , December 2020 , https :// www . fincen . gov / sites / default / files / shared / 314bfactsheet . pdf
16
Ibid .
17
This information was obtained directly from ChatGPT . It should be noted that ChatGPT sometimes writes plausiblesounding but incorrect or nonsensical answers . Please view the following source for more information : “ Introducing ChatGPT ,” OpenAI , November 30 , 2022 , https :// openai . com / blog / chatgpt
18
Ibid .
19
“ BSA / AML Examination Manual ,” Federal Financial Institutions Examination Council , https :// bsaaml . ffiec . gov / manual
80 acamstoday . org