Commentary: AI can be used to strengthen due diligence & anti-bribery compliance

Author: Merritt Smith, FCPA blog, Published on: 15 April 2019

"The truth about AI and due diligence", 5 April, 2019

AI is full of potential to improve the efficiency and effectiveness of due diligence programs... Although we cannot yet use computers to replicate the entire scope of a compliance team's work, certain areas of AI/machine learning research have matured to the point of offering substantial assistance... [M]achine learning algorithms can be applied to information about third-party agents, intermediaries and suppliers to assess the associated degree of corruption risk. The outcomes of these automated assessments could then be used alongside human review to augment a compliance program.

... [However] there are significant hurdles to overcome before machine learning can yield this sort of insight about bribery risk. Limited data is one... Criminal sentencing is one area where the use of AI technology has come under serious criticism for its possible inclusion of systemic biases... We should let this sort of danger serve as a reminder that while machine learning in its current state is well-suited for discrete problems that can be narrowly defined, it is not a complete solution to the broad scope of societal ills. Nevertheless, by making large quantities of information more manageable and intelligible, it can already help compliance teams better engage their own critical faculties in a more informed decision-making process.

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