Payment Systems To Financial Crime

Financial criminals aim to take advantage of increasing mobile payment traffic as companies undergo remote work, staffing changes, and other forms of pandemic-driven disruption. Those criminals are also using technologies such as robotic process automation and artificial intelligence (AI) to launch increasingly sophisticated attacks on digital channels for moving money. At the same time, relatively new, more lightly regulated payment platforms have expanded the risks associated with transactions. Indeed, mobile payments are proliferating, particularly in consumer sectors, yielding benefits such as speed and convenience. Organizations are also enriching payment data to enhance customer experiences and create new mobile service offerings, and developing countries are adopting tech-based payment systems to boost economic growth and assist unbanked individuals. Yet mobile payments can present often unacknowledged threats to brand and reputation and thus to stakeholders’ trust. Technology-driven payment service providers (PSPs) are driving many of these changes. While PSPs are not regulated as banks, they are subject to anti-money laundering and counter terrorist financing regulations and to laws related to bribery and other illegal payments. In many jurisdictions, they face increasing scrutiny from law enforcement agencies. PSPs, or organizations who own, operate, use, or partner with a PSP, must be aware of the risks in this arena, which  include financial, operational, cybersecurity, data privacy, regulatory, and legal risks. Any of those risks can rapidly translate to risks to brand and reputation, jeopardizing stakeholder’s trust in an organization.

Manage risks proactively

Given heightened risks, PSPs and organizations that use or are affiliated with them may consider upgrading their fraud and financial crime programs to adequately address threats to their systems, customers, users, partners, and reputations.

In addition to establishing a risk-based approach, organizations should consider the following steps:

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Broaden the view of risk. Financial crime covers a range of activities often mistakenly viewed in silos. A comprehensive risk assessment would encompass identity theft, account takeover, money laundering, fraud, bribery, corruption, and payments related to sanctions, drug and human trafficking, and labor exploitation. This assessment would seek not only to assess specific risks, but also to identify risks to brand, reputation, and trust across the enterprise.

Monitor potential criminal activity. Intelligent technologies for monitoring transaction activity can generate targeted coverage and reduce false positive alerts. AI and machine learning tools can be customized to an organization’s business model, users, transaction type and volume, and risks. Predictive analytics can identify emerging risks and potential issues that have not yet manifested as incidents. 

Build a culture of compliance. Given that technology innovation can at times outrun controls, some organizations may need to establish a culture commensurate with the financial crime risks they face. Such a culture beings with senior executive commitment to proactive detection, mitigation, and prevention. Senior leaders can also set a positive tone from the top and promote awareness of financial crime risks across the organization. Training programs and ongoing communication supported by leadership can create and reinforce awareness and compliance. 

Establish a whistleblower program. Establishing—or reinvigorating—a whistleblower program can help to reduce internal fraud risk while enabling early detection. By signaling that the organization takes financial crime seriously, these programs can discourage employees and contractors targeted by external criminals as potential accomplices, an all-too-common practice.

Engage with regulators. Many regulators are intensifying their focus on PSPs to better understand the role these providers play in the financial ecosystem and the risks and regulatory challenges they present. Active engagement with regulators can improve all parties’ knowledge of PSPs and trends in services, technologies, usage, and priorities.

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