AML Bridge Estonia
Money laundering facilitates some of the most horrific crimes imaginable. There are 40 million modern slaves, of which 10 million are children. 250,000 people are killed each year by the illegal drug trade. AML bridge Estonia is one small step that aims to reduce the flow of illicit money. Through this pilot, leading Estonian institutions can lead the world to a brighter future, with less money fueling corruption and illegal activities.
Breaking the silos of conventional AML
“Up until now, criminals have had the upper hand — they can collaborate while the banks cannot. Achieving a new crime-fighting standard is a complex objective and can only be established in collaboration with forward-thinking banks and regulators.”
What if banks could securely access third party intelligence from other financial institutions — giving them far more puzzle pieces than they’ve ever had before? It would be a game-changer.
That’s what AML Bridge Estonia will be doing — bridging the AML intelligence gaps.
Piloting the future
Emerging Privacy Enhancing Technologies (PET) coupled with new regulations across Europe encourage increasing cooperation to combat tech-savvy crime that harms us all.
In the AML Bridge pilot, four of Estonia’s largest banks will be able to access third-party intelligence from one another on a single data point to help strengthen their AML defenses. And show that collaborative crime-fighting is the new future in the fight against money laundering.
Four leading Estonian financial institutions — totalling nearly 90% of Estonia’s financial system — have combined forces, along with technology partner Salv, to develop and test new, state-of-the-art anti-money laundering techniques.
The AML Bridge pilot has also partnered closely with the relevant regulatory authorities including the Estonian Financial Supervisory Authority (FSA), Estonia’s Financial Intelligence Unit (FIU) and Estonia’s Data Protection Inspectorate (AKI).
Speed is crucial — the AML Bridge pilot formally kicked off in September 2020 and aims to have real-world results in only six months.
Validate the concept
Salv developed the idea with SEB and Swedbank as part of MasterCard Lighthouse’s accelerator program.
Result: Successfully validated interest in both banks, culminating in a Memorandum of Understanding signed by four of Estonia’s largest financial institutions.
Estonian branches of Swedbank, SEB, Luminor, and LHV — along with Salv — collaborate to determine the precise AML scenarios, validate legal requirements, and develop the technology for secure AML data sharing.
Result: Prove it’s possible, and useful.
April 2021 onwards
Based on the results of the initial pilot, AML Bridge will chart the next steps. It may mean expanding beyond Estonia and/or diversifying how the technology is used in Estonia.
Result: Prove it’s scalable
One of the first objectives of the Pilot is to select the underlying technology that best meets regulatory requirements and fits the use case.
AML Bridge will be built using Privacy Enhancing Technologies (PET). Modern PETs use state-of-the-art innovations to never reveal data sources and completely preserve privacy. They’re the Rolls Royces of data-encryption technology.
Sensitive data will be encrypted within each bank and never decrypted. PET’s facilitate safe, secure access to third-party intelligence within the bounds of AML, Bank Secrecy, and GDPR regulations.
Why is the pilot happening?
For today’s tech-savvy criminals, money laundering is still far too easy. However, financial institutions (FIs) haven’t been able to keep apace. Facing mounting regulatory and data protection laws, FIs haven’t been able to access the intelligence they desperately need to detect increasingly more complex criminal patterns.
Until today. With maturinging privacy technologies, coupled with new regulations across Europe that encourage increasing cooperation to combat financial crime, FIs can finally start working towards fighting crime together.
That’s why the AML Bridge pilot was launched — to make a way for FIs to access the intelligence they need from other FIs to effectively, and collaboratively, fight money laundering.
What is the pilot?
The aim of the AML Bridge pilot is to take the first step towards collaborative crime fighting because we believe it’s the only way to fight crime in the future.
The AML Bridge pilot will be between 4 Estonian banks and take 1-2 approved AML investigative opportunities and test that collaborative crime fighting is effective.
The aim of this pilot is threefold.
1. To prove that collaborative crime-fighting is the best way forward.
2. To prove that the Privacy Enhancing Technology (PET) enables safe, secure data-sharing within the bounds of regulatory and data privacy laws.
3. To prove a success in Estonia, and then enable other financial institutions across Europe to follow in Estonia’s footsteps.
Who is participating in the pilot?
The pilot will take place between four of Estonia’s largest banks, covering 90% of Estonia’s banking market — Swedbank, SEB, LHV, and Luminor — along with Salv Technologies as the technology provider. The AML Bridge pilot also comes with full cooperation and support from Estonia’s Financial Supervisory Authority and Data Protection Inspectorate.
The platform itself will be developed by Salv Technologies — an award-winning, Estonian-based startup providing AML technology launched in 2019 with customers in 6 countries.
What will be tested in the scope of this pilot?
There are a variety of use cases the AML Bridge pilot has been exploring based on usefulness as well as legal and technical scope. The first scenario that will be tested will be expanding lists of Politically Exposed Persons (PEPs) and their Relatives and Close Associates (RCAs).
In Estonia, the current lists of PEPs/RCAs — even those provided by well-known, industry-leaders — are missing large amounts of data and are often inaccurate.
As a result, each bank has then put in a large quantity of work tracking down RCAs and PEPs — essentially duplicating work that other banks are already doing. AML Bridge will test how much more effective the process can become if each bank can access intelligence on RCAs/PEPs that other banks in the pilot have gathered — as long as the person listed is a customer of the querying bank.
The plan is to add more scenarios as the pilot progresses.
What is the AML Bridge platform?
Salv developed the initial proof of concept for the AML Bridge platform in 2019 during the UK’s FCA (Financial Conduct Authority) Hackathon in London. In Spring of 2020, Salv then developed the pilot concept further during Mastercard Lighthouse startup accelerator with sponsors Swedbank Estonia and SEB Estonia.
Now, with most major Estonian financial institutions and regulators onboard, Salv will rapidly develop and deploy innovative technology. AML Bridge, for the pilot, will be built upon secure, privacy-enhancing technology and focus on 1-2 scenarios in which FIs can securely access third-party crime-fighting intelligence from other FIs in order to help detect criminal activity faster and more accurately.
How does the AML Bridge process work?
In general, there are two main ways the process may work:
1. Bank A may query intelligence on a certain customer. At that point, AML Bridge will return information, without revealing the source bank.
2. Bank B may find time-sensitive intelligence on a customer and feed it into AML Bridge. At that point, AML Bridge would then send an alert to any bank that also holds that same customer, while not revealing the original source of the information.
However, how exactly the system will work will depend on banks’ overall work processes. Salv has been conducting — and will continue conducting — extensive interviews with a wide range of stakeholders in each bank and participating organizations. This will ensure that the end result is useful and easy to use.
How does the platform technology work?
AML Bridge will be built using Privacy Enhancing Technology (PET). Today’s PETs allow far higher standards of data protection than the industry-standard Trusted Third Party (TTP) setups. Platforms built using PET, like AML Bridge, ensure that sensitive customer data is encrypted within each bank and never needs to be decrypted. There are a variety of emerging PET techniques and platforms that have been developed over the last decade and the most appropriate one will be chosen and deployed during the pilot.
What impact will the pilot have?
Collaboration across financial institutions on crime-fighting topics is a key strategy that can be used to combat financial crime.
Currently, though — due to regulatory, privacy, and technological constraints — financial institutions work in silos and thus have little hope in spotting the patterns of today’s organized, professional criminal rings. AML Bridge will help build the necessary bridges for banks to join a common crime-fighting network — making the life of genuine good customers better, while stopping more criminals and the illicit funds flowing through their systems.
What impact will the pilot have on bank customers?
The AML Bridge pilot is a Proof of Concept (PoC). Because its scope is limited to only 1-2 use cases, it will have no impact on participating banks’ customers during the six month pilot.
Over the longer term, if the pilot clearly shows that secure access to third-party intelligence amongst peer banks helps reduce financial crime, there will be several positive effects for everyday bank customers such as preventing fewer good customers from accidentally getting caught up in automated checks.
How is the pilot legal?
The legal framework of AML Bridge lies on three pillars — GDPR, the Banks Secrecy Act, and AML regulations. All laws and regulations must be satisfied in order for this pilot to not only launch, but to achieve success. Fortunately, recognizing the importance of combating the risk of money laundering, AML regulations across Europe have explicitly encouraged more collaboration between financial institutions.
In Estonia, the AML Bridge pilot has engaged Njord Law Firm to ensure each chosen scenario is legally compliant. The pilot has also partnered closely with the relevant regulatory authorities including the Estonian Financial Supervisory Authority (FSA), Financial Intelligence Unit (FIU) and Data Protection Inspectorate (AKI).
Why is this pilot happening in Estonia?
Estonia is a tiny, fast-moving nation that has innovated on tough problems over and over again. Home to Skype, Bolt, TransferWise, the world’s first e-residency, and NATO’s cybersecurity headquarters — Estonia has some of the most startups per capita of any European nation. It’s a perfect place to launch a groundbreaking, collaborative AML crime-fighting pilot that will change the future.
Are there any similar pilots / solutions out there?
The AML Bridge pilot is the only one of its kind to work on sharing vital AML intelligence between Financial Institutions (FIs).
However, there are several ongoing pilot projects across the world using PET (privacy-enhancing technologies) to combat various forms of financial crime in other manners — the most common being using or checking third-party data for KYC (know your customer) and joint transaction monitoring for AML. The best single source for information is https://www.future-fis.com/.
Most projects are in the planning stages or testing their pilots on synthetic data. Many of the projects, for instance in the UK, the Netherlands, and Australia, have been years in development and will take many more years to provide their first value for participants.
AML Bridge on the other hand — leveraging Estonia’s small size and the ability to move fast — plans to deliver real-world value to participants within 6 months or less.
What happens after the pilot?
After the pilot, in approximately 6 months, in the spring of 2021, the AML Bridge Pilot Team will evaluate previously-set Key Performance Indicators (KPIs). The Pilot Team will then decide whether to continue development, change course, or stop entirely.
If AML Bridge Estonia is successful, Salv is interested to expand use cases and capabilities, as well as conduct similar pilots in other countries across Europe.
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