Discussing Compliance and Anticorruption in Germany

Compliance professionals are currently facing what could be the most turbulent period of their careers. Regulatory scrutiny is at an all-time high, with enforcement activity continuing to intensify. Data volume, complexity and dispersion continue to accelerate at a rapid pace. Globally, new regulations are emerging, introducing overlapping and sometimes conflicting requirements that must be assessed, understood, operationalized and monitored. Meanwhile, expectations and interest surrounding generative AI are flooding organizational leaders with new technology considerations and questions. 

The intersecting points of these issues were central to discussions at the DKN Anticorruption and Compliance Summit this month. With attendees spanning compliance and legal officers from corporations across the DACH region, as well as law firm attorneys and consultants, sessions covered the topline issues compliance officers should be thinking about as they prepare for the year ahead. Additionally, recommended actions compliance teams should take to align their organizations to the current risk climate were shared throughout. 

How compliance and generative AI overlap

A key point is that before compliance officers can consider how to use generative AI, they must understand how their organization’s use of AI may affect their compliance frameworks and risks. Government authorities around the world are beginning to pursue legislation and enforcement activity for the use of AI within corporations. For example, in the European Union, the EU AI Act imposes a range of requirements for AI use in business, including ethical and privacy protections and transparency rules. 

Other jurisdictions are implementing similar oversight. The UAE’s Charter for the Development and Use of Artificial Intelligence underscores a focus on upholding ethical AI practices. And in the U.S., the Department of Justice recently updated its guidance for evaluating corporate compliance programs around the role of AI in committing, monitoring and prosecuting corporate crime. 

These developments are likely just the tip of the iceberg of the regulatory implications for AI use, and create a new area of risk for compliance professionals to address in their programs. 

Using generative AI in the compliance department

There are several early applications for AI and generative AI to support compliance teams and streamline burdensome processes. These were discussed at length during FTI Technology’s presentation at the conference and in other sessions. The most promising use cases covered are outlined below, but it’s important to note that different large language models can produce different results depending on the use case. Compliance officers must be mindful of using the right model, or combination of models, depending on the nature of the use case.

• Using generative AI’s summarization capabilities to review regulations, pending legislation, regulatory reports and other government-issued guidance. The AI can then use its learnings from those materials to compare against company policy documents, compliance procedures and activity to reveal gaps or contradictions. These potential red flags for areas of improvement or risk mitigation can be used to make improvements and to further train the AI for more accurate review of the environment. 
• Supporting fact extraction and identification of outliers in structured databases and financial records, alongside human review and oversight, to surface red flag transactions in support of financial crime prevention and enforcement. 
• Leveraging generative AI to support early case assessment, document summarization, fact finding and chronology development in e-discovery and document review processes. While these workflows still require significant human oversight, they can help streamline the discovery process and uncover important information early on in a matter. For compliance professionals, the use of generative AI in e-discovery can help to reduce the time and burden of conducting internal investigations or responding to a regulatory inquiry.
• Automatically compiling lexicons from an organization’s internal policy language and communications to monitor for and flag suspicious communications or transactions that are benchmarked against the organization’s baseline. This can support antibribery and anticorruption surveillance efforts as well as whistleblower cases, by identifying a violation against the company policy, code of ethics, etc. 
• Using different large language models . 

To learn more about how FTI Technology supports compliance teams with generative AI, visit IQ.AI by FTI Technology.

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The views expressed herein are those of the author(s) and not necessarily the views of FTI Consulting, its management, its subsidiaries, its affiliates, or its other professionals.