Future of Transaction Monitoring: Chasing the Holy Grail

Listen to this podcast to learn about the steps organizations must take to transform their transaction monitoring processes, the consequences of not transforming, and what is needed for the future to bring us closer to “ the Holy Grail.” Full transcript below.

To learn more about Protiviti’s Risk Transformation services, visit our website.

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[Powerful Insights – Future of Transaction Monitoring transcript]

Hello, this is Kevin Donahue, a senior director with Protiviti, welcoming you to another edition of Powerful Insights, the latest episode in our Transformation series focused on the future of risk and compliance. In this episode, we review the current and future state of transaction monitoring and explore the possibility of reaching the Holy Grail.

Our guests discuss how suspicious activity monitoring and reporting can and will be transformed by technology and the use of data, analytics and robotics, and the potential impact on reducing financial crimes. For this episode, Mark Highton, managing director leading Protiviti’s Financial Crimes Consulting practice, interviews Vishal Ranjane, head of global AML strategies, solutions and transformation at TD Bank, and Seth Twery, VP of client engagement at Tookitaki. And now, let’s go to their conversation.

Mark Highton: Welcome, everyone, and thank you for joining us in our ongoing Transformation series. My name is Mark Highton, and I lead Protiviti’s Financial Crimes Consulting practice. Joining me today are two Protiviti alumni: Vishal Ranjane is the head of global AML strategies, solutions and transformation at TD Bank, and he’s leading his bank’s effort to transform transaction monitoring. Seth Twery is the VP of client engagement at Tookitaki, a cloud-based AML transaction monitoring software solution.

In our conversation, we will consider the journey to the Holy Grail, and what and how the current financial crime operating models will change or need to change to meet this goal. Technology plays a key role in facilitating the changing operating model, but the data people and process dimensions are going to need to change also. So, Vishal and Seth, thank you for joining us. Vishal, would you like to share a little bit about yourself and your path to your current career?

Vishal Ranjane: My name is Vishal Ranjane. I am a Protiviti alum. I started my career as an engineer and started in supply chain and manufacturing consulting. I moved from manufacturing to financial services when the various financial institutions started adopting reengineering techniques, such as Lean and Six Sigma, and therefore, I consider myself an accidental banker. I’ve always been in risk functions, always focused on transformation, got back to consulting for a few years and now I’m happily back in banking. In my current role, I head up TD’s global AML strategy solutions and transformation group, which includes advanced analytics, building out a business-architecture mind-set focused on transaction monitoring, customer risk rating and focusing on the end-to-end journeys and how those customer journeys impact AML and other risk functions.

Mark Highton: Thanks, Vishal. Seth, over to you.

Seth Twery: Sure. Thanks, Mark. I have a long career in financial services — multiple decades. That does include a very enjoyable time with Protiviti. Most of my career has been at the intersection of technology and business and in a consulting role. I joined and started in financial crimes right after the PATRIOT Act was passed, as large tier-one banks began bringing in solutions to support their AML programs. I was a key part of those generation-one systems, and have been at Tookitaki for several years now, helping the industry change as well as putting in place modern technology to support financial crime prevention.

Mark Highton: Let’s start off with the first question, from a transaction monitoring perspective. Where do you guys see transaction monitoring stand today? What are the biggest challenges that the industry is facing in this in this regard? How effective do you think financial crime detection is? Seth, we’ll start with you.

Seth Twery: Sure. If you look at the industry, the key point for the banks here is to make sure they meet regulatory requirements. Your regulator is going to, through their examination process, identify the minimal requirements for you in that institution given your size and the risk appetite you have. What I have seen is, necessarily, institutions and regulated entities have to focus on the regulatory scrutiny.

In the last several years, one of those key things that I have seen is model risk management. There’s obviously a lot of debate in the industry on its effect and the need to actually prevent financial crime, but we all are living with it because it is a regulatory requirement. Then, the other real challenge is, are we preventing financial crime? Financial crime is a very strong business globally. It’s about $1.5 trillion, and it’s growing in an enviable 20% a year. Banks are a key component of the ecosystem to be able to get clean the money, and we need to do our part to maintain safety and soundness of the financial system.

Mark Highton: I noticed that, obviously, it’s the range of requirements and the growing number of penalties, because the penalties have increased significantly over time, but Vishal, what are your thoughts on this point?

Vishal Ranjane: I agree with Seth and you, Mark, that the penalties are definitely increasing, and from my perspective, I think that there are opportunities to increase the effectiveness of the program, but still, the bigger issues that we continue seeing are the inefficiencies, with false positives, just having too much of — the haystack is really too big to find that one needle out there. We need to be more agile. Banks need to be more agile. The financial services industry needs to be more agile. The bad actors are always one step ahead, and we need to keep pace with that change. We need to be able to leverage the newer technologies that are coming out there while we meet our regulatory requirements as well.

One other thing that enthuses me is the new risk-based compliance mandates that are coming out from the AML 2020 regulations, the new act, where they’re reiterating that financial institutions should implement reasonably designed risk-based programs and direct its resources to the higher-risk customers and activities such that it’s consistent with the risk profile of the financial institutions. This will be good for transaction monitoring as well, which is focusing more on our high-risk customers, reducing the haystack of alerts and making it more risk based. Those are some of the things that I’ll add on to what Seth mentioned.

Mark Highton: Do you think defensive filing is a problem too, or impacts or impairs the effectiveness of transaction monitoring activities?

Vishal Ranjane: From my perspective, it’s one of those things which is widely debated in the industry, Mark. I think like everything else, I go back to what my mother used to tell me: Everything that you do in moderation is good — don’t go too high or too low or anything — and I think that’s where banks need to find a balance between what are the types of SARs that they file? Too many defensive SARs is clearly not the way to go, but not having an indication that you lean out when you see something suspicious is also not the right approach, so I think it’s really a matter of finding that true balance between what the risk appetite of the individual banks is, and not overclubbing on defensive SARs.

The bigger question is, banks need to have a very well-defined strategy on what do you do if you’re filing multiple SARs on an individual? I’ve seen banks file 10, 15, 20 SARs on individuals or entities, but they don’t really think about demarketing the customer at that point or taking the next step, and I think what really needs to happen is taking the step back and defining what are the outcomes of filing these SARs, especially multiple SARs on individuals or entities, and what do you do as a result of that? It’s finding that middle ground by balancing the risk appetite of the business, but also not overclubbing on the SAR activities.

Seth Twery: If I could add a couple of words there, I’ll pull a theme of the risk appetite here. “Defensive filings” could be a little bit of a misnomer. The idea is, each institution — the AML officer, the board — has a risk appetite. They set policies on, within boundaries, the types of SARs or suspicious reports you should file, and really, it’s when you go outside of those boundaries. You can use machine learning to look back, and oftentimes, the ones that fall out of the norm are things that people say — if they were defensive SARs, they are truly either not risky, or they stick out. And for each institution, the idea would be to build into your policies and risk appetite the appropriate wording, so this idea of a defensive file becomes “no file” or “file.”

Mark Highton: Yes, agreed, and it’s human nature to a certain degree. If you think about that there is an incentive to file rather than not file. Institutions don’t get penalized for filing something, but they could get penalized for not filing, so there’s an inherent risk aversity there, which obviously, potentially, through this overclubbing, as Vishal calls it, could actually lead to minimizing or having a negative impact on your tuning and optimization processes because essentially, you’re tuning nonproductive SARs in to the new rules and scenarios and algorithms.

Seth Twery: I’d go back to a word Vishal used. Probably, we’ll pull through this a lot — agility. There’s a lot of friction for institutions to not be agile. They have a set of policies, the solution systems, and then how they actually investigate. To have all those work in concert today takes significant effort. Then there is the regulator — convincing your individual regulator— so the more we can adapt to having an agile framework, the more we will allow the institutions to support a risk-based approach that is actually focused on what’s happened at the time. We’ve seen it with the pandemic — significant change in how the bad actors have either attacked or moved through the financial system.

Vishal Ranjane: I agree with Seth. The one thing I will mention though, Mark, is, we are always trying to figure out ways to leverage whether it’s machine learning or whatever, but at the same time, we want to make sure that the data that the machine is learning from is accurate as well, to the extent it is. One of the points that you’re raising is definitely something that we look at, which is the efficiency of the SAR, and are we creating additional noise in the data, which is how the machine eventually learns? So, it’s definitely a consideration, Mark, that we have as we move forward.

Mark Highton: If we turn our attention now to transformation, let’s talk about, what do you think of the first big steps that an organization needs to take to actually transform? What I have seen through experience is, a lot of these banks and institutions — our financial institutions — tend to put Band-aids on the problem, as opposed to going in for the surgery. What do you think needs to happen?

Vishal Ranjane: I would put my response in three buckets: There’s inputs, there’s the actual process and then there’s the outputs. The inputs are really important because we’ve all heard about “Garbage in, garbage out,” and all banks have issues with data. They’ve gone through mergers and acquisitions. They have grown organically. They have grown by buying different portfolios. Historically, the data that they have is prone to error, just by nature of the data quality that they have inherited through these various activities. Everything that we have focused on as part of our transformation journey at TD is trying to understand, how do we get better with our inputs? How do we start thinking about data as a strategic asset for us as we move forward? That’s step one. That’s part of the activities that we’re doing on the input side.

The second thing is, we want to quickly learn. Let’s stick with the same concept of agility and some of the things that Seth mentioned earlier on as well. How do we apply advanced analytics on our data and have some sort of a sandbox environment for us to test and learn quickly? Try out various scenarios. Understand what are the topologies and the red flags out there? Keep a pulse on what are the new things that are that are coming up in the industry? Lots of focus on cyber, which is a predicate crime. Lots of focus on ransomware. How do we really incorporate all of that, at least in our thinking, as we build out our program from a transaction monitoring perspective?

We need to also think about the outputs. That’s clearly something that has increased the costs. You talked about costs a while ago as well, Mark, so what is the way to reduce our outputs — i.e., the false positives that we see? The way we have attacked it is, we have really spent a lot of time in building out a pretty comprehensive road map that starts with data, and then we are focused on pretty much all of the elements of the programs. The processing, the people, the technology, as well as the outputs, not just starting with the data, but also focusing on the people and the technology components, I would say, are some of the things that would definitely benefit organizations.

Mark Highton: Yes, absolutely, and Seth, I’m assuming you’ve got similar views.

Seth Twery: Actually, a little different here. Data — just talk about data for one second. To start there, I don’t think AML programs should be hindered with the data challenge, because that’s an institutional problem that has been building for decades, and as an AML program, the more you’re focused on solving the data problem for your entire institution, the less you can focus on your actual needs and requirements. This should be an enterprise program that is ongoing, particularly for tier-one institutions.

The sins are not from the AML program. They are from five, 10 decades of history, tens of millions of records, dozens and dozens of acquisitions, and it is something that, regardless of data quality, you still have to do your job. You need to find ways to leverage as good as it is, so it’s absolutely a problem.

I suggest, or adapt, that it is an enterprise issue, not a financial crime issue. What you should focus on is having analytics and capabilities within transaction monitoring to do the best possible, given the reality of data where you are. It’s a major problem, but let’s try to identify the help regardless of it. Vishal, to the extent you guys are, it’s a reality. I recommend and suggest you try to push that where it resides the across the institution. There are plenty of compliance and regulatory pressures for an enterprise-level data governance requirements.

One of the actual transformations and first steps — I think of it as a heat map. Every institution has little varying needs. A key part here is Band-aids — one of you used that word before. It is easy to identify a symptom to try to solve, and I think you have to balance needing wins with how long it’s going to take — time to value of delivering on a project — and whether you’re addressing core issues or an interim problem or symptom. That varies. Whether it’s a core banking system you’re trying to replace that has been there for 40 years or a transaction monitoring system, you need to find ways to break that into pieces but end up solving your fundamental issue.

Mark Highton: What about in terms of transformation itself? I think what you’re saying is, the return on investment on a transformation is obviously something that comes into play before deciding whether to invest in new systems or changing anything that’s going to cost a fair amount of money. Would you see it as more of a big bang approach to reimplementing a system, or doing it in smaller chunks, piecemeal, so that each success funds the next part of the journey of transformation?

Seth Twery: Historically, huge, big bang projects have very high risk, but conversely, sticking without replacement for too long also generates massive potential risk, so you have to find that balance. I would not recommend that a transformation start with, in simple words, rip-and-replace. There’s way too much complexity.

One of those that I would — maybe a lens to look at it, find ways to chunk it up, but you use the words “right people.” At the end of the day, many of our large institutions have scores and scores of people that use this system every day, and having been a systems integrator for decades, what often happens, if you put in this great new system, we all see these users as customers of a bank or whatever large entity, and too little focus is put on the actual usage each day and to make it effective for end customers. Start with the people — look for the people — and get inputs from the actual end users and find ways to break it down into discrete deliverables that you can gain value from as you go.

Vishal Ranjane: Like everything else, if you don’t chunk it up and you don’t make it interesting, human nature is, you lose interest if it’s not the next shiny object, so it’s really trying to balance the two activities. We are fortunate enough that our leadership in the bank — the board of directors — sees the value of financial crime and new technologies that’s going to help us move into the future. The whole process that we have is, build a business architectural map that shows us if we spend a dollar, or if we spend a hundred dollars in piece A or piece B, what’s the value of that money that we’re spending? What do we get or not get if we don’t spend that money?

We’ve spent a lot of time in building that correlation, and that actually makes the job pretty easy because when we go and ask for money now, or we ask for funding, there’s a direct correlation between how you’re going to use the money — get the budget — and how you actually see the benefits. We’ve actually gotten better at doing it over the last couple of years, so we have demystified to some extent that this is not necessarily an open checkbook or a money-pit way of putting things in and not getting the benefits. We can actually show the correlation — and you might not see a direct correlation, but there’s also indirect correlation.

Mark Highton: What we’re starting to see now is banks starting to think about how can they, in a big way, transform by consolidating onto single platforms, moving to centers of excellence across business, and bringing in more AI and machine learning and new techniques? It’s interesting that that’s going to be where more and more banks are going over the course of the next few years.

Let’s ask this question, then: What are the consequences of not transforming? Seth, what do you think?

Seth Twery: The consequences of not transforming — first of all, we have to put the context in that the world is changing constantly, and that change is accelerating. If you think about our cell phones, how we do our work, the work from remote with the pandemic, the world is changing around us, and financial crime is actually accelerating, and, going back to a word we used earlier in the conversation, agile.

We need to always try to be at least on the leading edge, if not bleeding edge. We know that laws and regulations adapt slowly, and that there is this gap between the changes being pushed by the regulatory groups and the bad actors. I think it’s an adapt-or-fail-type situation. This is where you see the huge fines with global institutions that have not taken action, and the consequence, when I say fail, it is going to be somebody’s big problem. Another example I’ve used is multifactor authentication and the ransom attacks that have occurred. People that haven’t changed have had massive issues. If we look at it from other institutions, adapting that within financial crime, I believe the same thing: They’re going to come to your doorstep versus the next guy’s doorstep.

Vishal Ranjane: There are a couple of factors that I’ll put out there in addition to what Seth mentioned. We’ve talked about costs before. The cost of compliance has only increased every year significantly to a point where, right now, it’s pretty unsustainable. Organizations, in AML, especially all the tier-one banks and even the tier-two banks, have at least tripled their size in the FIUs, if not more. They recognize that this has become sort of a money pit and increasing their staff to take care of a blunt instrument which has been put in place in the past. The regulations are not getting any less. In fact, there’s an increase in the regulations, and the bad actors are also innovating, themselves, and with new predicate crimes — I talked about cyber and ransomware before — those add additional complexities.

There are also differences between “Do I need to keep the bank safe?” as well as the factor of reputational risks that banks need to look at as well: Do you want to be in the headlines related to any of these financial crimes? The answer is, absolutely not. All of these together are definitely changing the conversation at the C-suite, and the board of directors.

Seth Twery: Let me jump back in for one thing. One thing you might want to look at that’s not as obvious: The tripling of the cost is a real thing, but oftentimes, we look at what to add, not what to take away. A lot of the institutions are looking for new technology or building new technology. There’s a whole suite of firms like Tookitaki that are building out these great capabilities. The question is, over time, you should build to reduce not just operating costs — well, people costs — but the technology, or change policies and procedures. I would say one insight, having seen lots of just different institutions, to make sure you push to reduce old procedures or process or oversight or technologies over time to try to keep that cost balance.

Mark Highton: Vishal, what are your thoughts on what do you think the Holy Grail is? What do we want to get to? Is it 1:1? Is it possible to get to a one-alert-one-SAR filed?

Vishal Ranjane: I look at it from a risk lens perspective, Mark, but if we do imagine what the Holy Grail is, I genuinely believe that the work we do at banks is at the forefront of fighting financial crime, so it’s optimizing the effectiveness of the program while being more efficient doing it. I think the theme of this podcast is definitely agility, and agility is key in this instance as well.

For me, even though Seth had a different opinion on the data, and the data management and the governance of it, I agree with Seth that we can’t solve for the problem of the bank. We have to think about it from an AML perspective. I do think that a reliable data management or governance program that’s effective will increase the confidence of the inputs that get into transaction monitoring so we can increase our reliability on the data that we get as well. Hundred percent agree: We can’t solve the bank’s problem, but we can definitely raise the right issues and try to get the right management around the data, which is a bankwide initiative.

I do think that an effective transaction monitoring system that balances the new technologies, machine learning as well as the rules-based engine, depending on what the type of scenarios are and what the risk appetite of the financial institution is as we move forward, and also a very targeted and ongoing effort. It’s not a point in time. It’s an ongoing effort to reduce the false positives, getting the better outputs that, in effect, will increase the SAR-to-alert ratio that you mentioned. I hope it can be 1:1, but maybe not, but really, once we add all of these three things together, which is something that will allow us to transform our banks and get to a better output, is what we look for. I think these are the three principles that we have applied consistently in a lot of our AML transformation initiatives as well.

Mark Highton: I want to push you’re here, Vishal: In terms of thinking, the view of the art of possible, is it possible to get to maybe a 2:1 ratio then? I mean, if we can use AI and machine learning to train a car how to drive itself, couldn’t we also use AI, eventually, and machine learning to train the system to be able to clear alerts — automate?

Vishal Ranjane: The day that’s available, I’ll sign myself up, for sure, so I would love for that to happen. Actually, I’ll work with whomever to reduce that alert-to-SAR ratio, but we also have to be pragmatic. I do think that reducing that ratio is definitely going to help. If you get to the 2:1 ratio, Mark, maybe you and I can have a separate conversation for sure.

Seth Twery: I have the answer to the system technology that can do it.

Mark Highton: What do you think?

Seth Twery: Yes. Alert-to-SARs, to me, is a symptom. If we step back and have the perspective, what are we doing? We’re looking for bad actors, right? Alerts are supposed to be identifiers of risky behaviors, and ultimately, it isn’t even bad actors. It is what regulators have identified in large part as red flag activity.

I will never forget 20 years ago, when I implemented the first large transaction monitoring system in one of the U.S. institutions — this is a top five. The system crunched away for two days, and we got this alert, and they were like, “This is absolutely cash structuring.” It was a Girl Scout troop account, so look, what we are looking for is the bad actors, and therefore, what I would say the Holy Grail is, is risk-based behavioral monitoring of real people.

To me, this is more about customer risk. Transaction and behavioral monitoring and these alerts are essentially indicators of risky activity. I think any AML investigator doesn’t take an alert and go “Is this alert SARs? Am I looking at somebody that’s perpetrating financial crime?” We need to be aware of alert-to-SAR ratios because that is operating cost and effectiveness. We have a client that is at about a 45% alert-to-SAR ratio. However, many people have pointed at them, saying they’re generating a lot of SARs that mean nothing. The Holy Grail, I would point out to the industry, is true behavioral monitoring of real human beings that are risk-based, looking for bad actors.

Mark Highton: Yes, and I tend to agree, and the other thing that we should probably factor in here is, of those SARs that are actually filed — I was reading a BPI study that was done in 2018 — only around 4% of those were actually of interest to FinCEN and the law enforcement agencies. That’s an awful lot of SARs that were filed. I think they were filing something like two and a half million SARs per year. That’s an awful lot of SARS, which don’t seem to be being leveraged. This is the other piece where it’s getting that feedback from FinCEN and the law enforcement agencies to actually understand better what a good, productive SAR looks like so that can help tune the systems going forward.

Seth Twery: There’s been a discussion for a long time, but absolutely, feedback loop across law enforcement is super critical, and it’s super critical for new AI machine learning to help get that feedback — not just the filing a SAR, but what SARs generate tactical and strategic value for law enforcement.

Mark Highton: Yes. I totally agree, and I think that’s something that’s pretty critical in the big step forward that we need to make from a transaction monitoring standpoint become more effective and efficient, because it would help start to drive out those false positives even more.

Seth Twery: Alerts generate not only work for your investigators. There is also a potential customer impact to good people. We don’t hear it a lot, but there is a customer-retention and customer-satisfaction component for generating the noise in the system.

Mark Highton: I agree, and I guess the other thing that would be interesting to get your thoughts on is, assuming we’re driving away the false positives and reducing the number of alerts, what are the ways that we can become more efficient and effective in actually handling and dispositioning those alerts and doing investigations?

Seth Twery: It is interesting here that a lot of the technology that is out there, and that is being adopted, is trying to do the mundane data collection — external addition of data, or simply connecting the systems with that an institution has within itself, and there’s technology to do that generally robotic automation kind of tools. That is one of these Band-aids treating a symptom. At the end of the day, yes, that needs to be done, but instead of doing it on 100 alerts, we should be doing it on the 50 that are truly risky to the institution. That’s eliminating nonvalue activity and nonvalue work — a way to free up both capital as well as resource to focus on the risky activity.

Mark Highton: Basically, what you’re saying is, we shouldn’t be automating things that shouldn’t be done in the first place?

Seth Twery: Correct.

Mark Highton: I agree with you. Vishal, have you got a view on that, or do you have a different view than Seth?

Vishal Ranjane: Yes, I agree with the concepts in theory. I do think that there’s also something that we haven’t talked about, which is collaboration with the industry at large. What I mean by that is, it’s probably easier in Canada than it is in the U.S. A lot of the customers bank with multiple banks. Many times, the alerts and the dispositions of the alerts are only looking at the activities that you had within your own entity, so talking about the Holy Grail, and what’s the art of the possible, wouldn’t it be great to understand the relationships and the alerts? Maybe you could take care of some of the privacy issues by encryption of the customer keys, but wouldn’t it be great to understand the activities across the industry at large and across the banking sector and make your decisions then?

There’s definitely some movement in the industry. We are participating in a few of those as well, but it’s in its nascent stage, and getting to the right alerts, understanding the behaviors of the customers, as I pointed out earlier, is going to be key in really getting to those bad actors quicker, and not going after the Girl Scout cookie example that Seth mentioned earlier. It’s really important to know about the customer, along with the transaction monitoring, alert investigation, and the only way you really know about the customer is to get more insights outside of your firm as well, and the partnerships with the other FIs would definitely help.

Seth Twery: That is an incredible point, and I think it is, maybe going back to the Holy Grail, if you think about what technology has done and this sharing, if we look at other industries, the highest-value-capitalized companies on this planet are driven from advertising dollars, and instead of hitting mass market, you have companies like Facebook, Google mining the data, brain hacking, so that they leverage advertising dollars and make huge money from us as people.

If we can apply that to identification — and it can’t be an individual institution, it does have to be cross-institution, as in sharing at the industry level, to Vishal’s point — the technology is out there. That shows, if we look at that as a different application analogous, that the analytics and the technology are there. We have to find ways to use it, and we have to get out of our own way to help make that happen.

Mark Highton: Yes. I agree totally with both of you. It’s fundamental, the cross-industry, cross-institution collaboration is critical to certainly generating a much more effective crime-fighting industry because that’s the only way. We have to become more sophisticated to actually defend against more and more sophisticated criminals and bad actors. I think that’s fundamental to the change that’s needed.

Guys, I know we’re running out of time here, and it’s really interesting talking to you guys. One quick question, then, to finish up. What do you think of the AML Act 2020? Is that going to be positive for transaction monitoring progress toward the Holy Grail?

Seth Twery: At the end of the day, the lawmakers are probably slow, but I think they put it out there, and that the industry absolutely will be changed. Could it have gone farther? Absolutely, but it’s good, and it’s going to drive change in the industry.

Vishal Ranjane: I agree that there’s definitely a positive movement with the AML Act, though there’s a little bit more that can and will be done. The two things that are exciting are their concepts on risk-based compliance as well as the innovation components, which is, we’re really scratching the surface right now. Those are definitely exciting points that they have raised, and I feel that that’s definitely going to increase rapidly as well.

Kevin Donahue: Our thanks to Mark, Vishal and Seth for an informative conversation about transaction monitoring and financial crimes. Please like and share this content so that we can continue to bring you episodes featuring leading executives and their views on the future of risk and compliance. To learn more about Protiviti’s financial crimes consulting services, visit us at Protiviti.com. I also invite you to subscribe to our Powerful Insights podcast series and review us wherever you get your podcast content.

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