This episode covers how organisations should re-equip themselves to combat money laundering in the digital era. The panel discuss whether the responsibility for AML should be solely limited to the compliance team, what processes can be improved across the organisation to combat AML, how departments can work together more effectively to fight money laundering, how AML fits with the broader context of digital transformation, and how AML can be shaped to enhance business growth, rather than be seen as an obstacle.
Our guests for this episode include:
- Mélisande Mual, Managing Director, The Paypers (and moderator)
- Livia Benisty, Global Head of Business AML, Banking Circle
- Christopher Caruana, VP of AML Solutions, Feedzai.
- Antonia Michail, Deputy Anti-Money Laundering Compliance Officer, Digital Payments, Nuvei
- Leslie Bailey, Vice President of Financial Crime Compliance Strategy, LexisNexis Risk Solutions
Russell Goldsmith [00:00:05] Welcome to the Knowledge Circle podcast from Banking Circle, my name is Russell Goldsmith and in this episode, we’ll hear the highlights from our webinar on Implementing AML across your organisation, hosted by Mélisande Mual, Publisher at The Paypers.
Mélisande Mual: [00:00:25] A successful AML strategy for the digital era is not just about regulatory compliance, nor should it be limited to the compliance function. Now, and in the future, fighting money laundering means having the right technologies in place, optimal organisational design, high quality data captured from a wide range of sources, and the widest possible collaborative approach involving national and international regulators, as well as external partners and clients. My name is Mélisande Mual, publisher of The Paypers. Today we will talk about what it takes to effectively implement AML across your organisation. We have a number of experts in our panel, and I would like you to introduce yourself briefly. Tell us a bit more about your role in the company and your background in AML. So, Livia, could you please take it first?
Livia Benisty: [00:01:12] Sure. Hi, everyone. I’m Livia Benisty. I’m head of AML at Banking Circle, previously at Citi, BBVA and Comply Advantage. So, a range of experiences across large international institutions and smaller start-ups and technology companies.
Mélisande Mual: [00:01:27] Cool. Antonia.
Antonia Michail: [00:01:28] I’m Antonia Michail, and I’m the Vice Deputy MLCO. I’m responsible for supporting the company’s compliance with AML and CTF regulations throughout Europe. My role includes developing and delivering training programs, investigating, reporting suspicious activity, and along with the rest of the compliance team, guiding compliance relating to new industries and regulatory issues.
Mélisande Mual: [00:01:50] Great. Thank you, Antonia. Leslie.
Leslie Bailey: [00:01:53] Hi. My name is Leslie Bailey with LexisNexis Risk Solutions where I’m the Vice President of Financial Crime Compliance Strategy and Global Product Delivery Strategy for LexisNexis.
Mélisande Mual: [00:02:05] Thank you. Chris.
Chris Caruana: [00:02:08] Chris Caruana, Vice President of AML Solutions here. My main focus is just making sure that our client’s voice and market direction get included in some of our product thinking and long-term strategy. Recovering compliance officer as it is, working at a variety of financial institutions. And I once was a broker-dealer regulator as well too. So a unique position to kind of see all sides of the table when it comes to some of these conversations, which is been helpful and also detrimental to my career in some respects.
Mélisande Mual: [00:02:39] Brillant, Chris. Okay. So today we will discuss the following four topics. We’ll talk about AML responsibility. We will talk about how departments can work together more effectively to fight money laundering. We can talk about how AML can be shaped to enhance business growth rather than be seen as a block. And we’ll talk about the battle against AML and the need for both national and international cross-industry collaboration. So obviously the responsibility for AML is not limited to the compliance team. Moreover, the sixth AML brings broader liability and more severe punishments on an organisational as well as on the personal level. So how can compliance teams help the leadership raise awareness and create a strong AML culture?
Antonia Michail: [00:03:26] Sure. It’s a very interesting question. Thank you for that, Mélisande. So let me start by saying that no man is an island. So, no matter how many systems you bring in or how technologically advanced the company is, we’re still humans. And this needs to be taken into account. So as everything starts it’s affected by our actions or lack of them. Having said that, each company has three basic lines of defence that always need to be utilised. So, the first line of defence being the sales and account managers need, of course, most of the support in order to understand and implement the company’s policies and later on to explain to the merchants why these policies are in place. Besides the obvious factor of building robust policies and related training, technology usage and management awareness, that address the how to do it. The way I see it, it’s also important to assist all stakeholders to understand the why to do it. My main focus, in general, is actually to make each and every person participating in my training to realise that his or her actions, or lack of them, do affect other people as well as their company’s reputation and well-being.
For example, let’s say drugs trade or trafficking, traffickers exploit vulnerable people for financial gain by tricking or forcing them mentally like into prostitution or sexual exploitation, and less common to begging and then moving or selling their organs. So, trafficking in human beings is often linked to other forms of organised crime. And for example, the UN estimates that it’s the second biggest source of illicit profits after the drug trade.
Whilst the estimated number of people being trafficked per year is globally, 2.45 million whilst 1.2 million are children. This is just an example of 2022. So, when your trainer makes you listen to these numbers and gives you real-life examples, you get to realise that you need to be vigilant. Compliance stops from being just ticking the box procedure and suddenly compliance gets a totally different meaning. By pushing the message of personal responsibility and accountability and at the same time introducing your audience to the reasoning behind regulation is of importance. We don’t neglect the other factors, but it’s important to actually connect real life with compliance and why it is there. They’re not just only have to implement it.
Mélisande Mual: [00:06:06] Thank you, Antonia. Livia, you have years of experience in AML. What have you learned and how do you apply your learnings and your current role? What is effective in creating a strong AML culture?
Livia Benisty: [00:06:17] I think that there is a distinction between creating a strong culture and having an effective program. I think that you create a strong culture around it by showing the videos and listing the stats and humanising it. I think that’s how you get people to understand that it’s important and why it’s important and making it emotional.
I don’t know if that always translates into an effective program outside of beyond just compliance. I’m first line, but first or second line can create their own risk programs in order to get sales buy in. And the way to do that is to get a salesperson to sign off on the client assessment form at the end of the risk analysis, say, I acknowledge the risk this presents to me, to the bank and I accept that I own that risk and I take it on because if you say to a salesperson, are you prepared to accept the incredibly high risk that this client comes like, yeah, no, I acknowledge that. But it’s going to make us loads of money. And if their incentive is purely target-driven, you’re not going to end up with an effective program. They may have a good culture around it, but that culture around human trafficking, especially when, as we’ve discussed as a group before, you don’t always see the direct results. You don’t get that feedback; you don’t know what you’re processing or you’re not processing. Sometimes you have to go on blind faith that you’re making a difference without that strong connection between your direct action and the direct output. That humanising of the story gets lost when the bonus cheque comes around. So, I think it’s a combination of making it real, making it emotional, but then you have to make them incentivise to follow that as well.
Mélisande Mual: [00:07:42] Let’s go to the next topic, which is about the collaboration between departments and how they can work more effectively together. We see more and more companies are starting to realise that an organisational barrier between cybersecurity, anti-fraud and anti-money laundering teams makes it harder for banks to prevent fraud and conversely, easier for cybercriminals to attack. So, Leslie, how are these different silos positioned and what led to this approach? Why are they so separate?
Leslie Bailey: [00:08:17] This is just something, that really resonated with me in a number of ways, because I think at the centre, when we talk about the expansiveness of an effective program across an enterprise, really what’s at the centre of that is financial crime and how people advance their activities for financial crime. Then the behaviours, and I think potentially what we saw last year with an acceleration around digital just further underscored this and candidly the need to drive towards greater collaboration around this, a common understanding, if you will.
So you have all of these different areas of institutions that have a little bit of a different remit, which kind of goes back to the thinking before and what Livia was highlighting in terms of what makes an effective program, that you have fraud that is looking towards your immediate protection, your AML group, who is looking towards regulatory protection, and then cyber that is looking towards protecting the data and just the continuity and the consideration given to all of those areas. Collaborating, coming together to provide and develop insight I think is where you really get a true assessment of risk – leveraging tools, effectively leveraging dialogue, and sharing information to get to better insights. I think that’s where just that dialogue, that conversation Antonia mentioned early on, that personal responsibility, when you have people in each of those individual areas that understand the why behind what they’re doing and collaborate to make it more effective in terms of implementation and ascertaining what true risk is within an institution, overall, you have greater success.
Mélisande Mual: [00:10:17] Thanks. I would like to go to the third topic, which is very much about AML and how it can be enabled or shaped as a whole function to enhance business growth rather than seen as a block. And I would like to kick off this discussion. I would like to start with the client perspective. Basically, the perspective of SMEs, particularly those SMEs that have a cross-border operation. Because AML for these customers can be seen as a huge business block, it’s very hard for those SMEs to open up accounts for a branch outside their domestic market, even if it’s within the same bank. We all know this can take months. It can be a business block. But I would like to understand, Livia, why do particularly big banks fail in speeding up the process for their own, let’s assume we talk about legitimate customers for their own legitimate international business customers to open up an account in a country, another country, but within the same bank organisation. What makes it so hard?
Livia Benisty: [00:11:22] I think SMEs are in a particularly interesting position. I think they’re kind of notoriously underserved in the market anyway. And if I think sometimes about why, I think no one really knows how to categorise them. It’s just an issue we’ve come across recently, like I’m trying to better drill down into certain data to use for monitoring, and I’m seeing that previously some of our clients will categorise them as privates and some will categorise them in the corporates. And I think that that was always the root of the issue, is that no one really knows what to do with them.
So the risk of a peer-to-peer transaction is that it has no commonly known purpose behind the transaction. So that’s why that’s risky. And whereas corporates you’re usually selling a good or service, but equally, most money laundering goes through offshore companies or little corporates because it gives the air of legitimacy and SMEs are right in that Venn diagram of that risk, but no one really understands what they’re doing and I think that’s one of the reasons they’ve been quite tricky to manage from a risk perspective and why big banks are failing not just to the SME population, but cross-border. Partly big banks across borders have been established through a series of M&A. They started somewhere and they bought little banks. Even if you take purely within the American market, there’s often a community bank and there’s everything’s very dispersed.
But especially when you’re going international, it’s acquiring tier two and tier three banks across the world that are operating with very different standards, very different systems, different CRM, different access to payment systems, different rails. And that’s really hard to merge. It’s really hard. So when you are trying to onboard a customer from the UK into your, let’s say, US branch or Asian branch somewhere else, you have no way of transfer, first of all, data sharing, you’re not really allowed to. So, we can take that as a separate issue. There are certain issues with where you can share data even within an organisation across borders, but transferring that information over, having a client already set up, giving them the same access. And then also on top of that, trying to mitigate against different standards of AML between the two usually means that you have to set up the client from scratch and they are a new client. So, it leads to a really negative experience. And I think that the summary of that is that it’s a combination of the way in which these banks were established and that legacy infrastructure that can’t be aligned and then the differing regulatory standards throughout and it can be gotten around. But big banks are at a big disadvantage in doing so.
Mélisande Mual: [00:13:48] Yeah, it started as a business opportunity for other, for smaller banks or for PSPs/acquirers to step into this opportunity and service these underserved SMEs.
Livia Benisty: [00:14:00] Definitely. And I think that if you take a bank and an infrastructure provider like Banking Circle with this provision of things like virtual accounts and the ability to offer payments that look local, even if the host account isn’t, by providing that kind of direct connectivity into multiple markets, we’re seeing our PSP and acquiring clients starting to think about how they can offer bank accounts to their merchants. So, the acquirers really have the hold on the merchant, especially the SMEs. So, they’re acquiring all of their transactions. They now have the ability to provide them with the means of making payments with those proceeds of sales. So, it’s a natural next step. And if those entities are starting to be able to offer broader payments because they’re connected in so many more places, I really think that would absolutely take the place of a bank and end up overtaking it. The issue is whether the banks will continue to allow that. It’s not nesting as such, but ultimately somewhere along the lines it could end up being nesting and there’s a different risk there. And is the industry ready for that?
Mélisande Mual: [00:15:02] Interesting. Yeah. How do you see that uncertainty in that you’re a PSP acquirer, and Nuvei is one? So how do you see this opportunity?
Antonia Michail: [00:15:09] I totally agree with Livia. And in addition to what Livia said, I mean, we all agree that we live in a globalised economy and so we’re currently living in an unprecedented crisis. I mean, the businesses that have suffered more are the SMEs. So, for the repute in general of the economy, through the creation of new positions, innovation is needed, Nuvei being a PSP acquirer is proud also to support the SMEs and innovation in a sustainable way.
Mélisande Mual: [00:15:44] OK. Thank you, Antonia. So, within this sort of, where is the business growth and where is the opportunity? Well, automation in AML has improved efficiency. The traditional rule-based approach to transaction monitoring in particular is built on outdated technology and does not serve banks or payment businesses well enough. And using these aesthetic behaviour rules we capture only one element of the transaction, the industry sees false positive rates between 97 and 99%. So, I guess there’s a huge business opportunity here to do a better job here. So, Leslie, what is the business opportunity if you do AML in a more effective automated way?
Leslie Bailey: [00:16:31] I think there are a few actually. So, if you think about the way that AML has historically worked, it’s using very reactive tools, right? So, there are a lot of organisations that are still leveraging batch processes, things of that nature. And I think with faster payments and digitalisation there are interconnected threats. So, you have to have more real-time capabilities. You have to just look for opportunities to be more deliberate and share information across your organisation, risk-relevant data to help look at the whole picture and help support what you think in terms of threat intelligence. If you’re sharing information that way, then you have the opportunity to be very strategic and save your organisation money. I think you then are really deploying your most trusted assets or your human capital, if you will, having the right level, looking at true risk across your organisation.
And the true risk is ultimately where you want to get, you want to reduce the false positives, things of that nature, the quick hits, easy opportunities through automation, machine learning, things of that nature. But it’s reducing your overall exposure and redeploying those assets in a very meaningful way that can ultimately save your business money. I think just that increased collaboration oftentimes helps support that. You’d be amazed at what can be accomplished in a five or ten-minute conversation around something versus hours of investigation or waiting on a batch to go through. And it goes back to reducing the friction for the customer, ultimately. So, all of those are ways that you can be more effective. I would say looking at how things are moving from a digital perspective that speed is key these days, the ability to quickly assess and move on. Otherwise, organisations are going to become overwhelmed just going through the process of those alerts that are created. So just a few thoughts there.
Mélisande Mual: [00:18:48] Chris, any thoughts from you on reducing this huge number of false positives?
Chris Caruana: [00:18:55] Look, if there was a silver bullet, I think everyone would have that right. But we talked about data cleansing and data sharing. We talked about greater collaboration and communication between the teams. We talk about understanding the risk across these different functions, whether it comes from a fraud angle or an infosec angle or an AML angle. How can that be combined to form a more great or greater informed picture when you’re making decisions?
In the interest of the topic of this conversation, implementing AML across your organisation, there’s an opportunity here for your second line to also help out your first line and be a business driver as well, too, right?
So, if we think about the information that compliance teams that control functions have across an organisation or the picture that they have of your customers and your client base, wouldn’t your business love to have that same sort of picture of the risk that a client poses to your organisation when it comes to wanting to expand the relationship? Right. Couldn’t they remove a bunch of customer friction, say, roadblocks throughout business opportunities and throughout relationship expansion with the data that your second line teams have alone? Which is why I think organisations like Banking Circle that have some of those control functions also embedded within the first line are also thinking about it in that way. If I can already utilise the risk picture that I have right now, at least at the second line of defence in my first line of decision making, isn’t that a pure goal for us? So again, it comes back to organisations taking that step to put resources behind and sort of understand and explore this in a deeper way and see where they can leverage what’s already being done within their organisation at the AML function, at the control function.
Mélisande Mual: [00:20:45] And use that insight to basically recognise the behaviour of good customers as well, for the better.
Chris Caruana: [00:20:53] Absolutely.
Mélisande Mual: [00:20:54] Certainly, yeah. Very good point, Chris. We will move on to the last topic, which is about data sharing across industries, because in the industry we see banks starting to work together in data sharing initiatives. In the news, we’ve seen a couple of ones you can basically discern two. One is more into the development of KYC utilities. There is an initiative in the Nordics called Invidem and through this Invidem, the founding banks have developed a common standard for KYC information that is made available through their KYC services and platform.
So, it’s basically standardising information. There’s also another example in transaction monitoring, which started recently, it’s the TMNL, which is a Dutch initiative, founded and funded by five big Dutch banks, and they are building a transaction monitoring platform and focusing on identifying unusual patterns in payment transactions, starting with overseeing all bank accounts of these five banks. And we think this collaborative approach definitely makes sense.
Let’s talk a little bit about these data-sharing initiatives. Livia, what is the incentive for banks to join a TMNL or to join a KYC initiative? What is the incentive for banks and what are the challenges to making this a success? Because we’ve also seen some initiatives be paused or failed. For instance, one in Singapore, started in 2017 and stopped two years later. So, what is the incentive and what are the challenges for banks?
Livia Benisty: [00:22:34] I think it really depends on how they’re set up. I mean, on the face of it, the obvious incentives are if a KYC utility in the way that I would understand it to be and it does differ because when I look at how they’re practically implemented it isn’t what I would think a KYC utility should be, but if it is a means of tapping into an approved standard of due diligence for a given corporate or client, whatever form that client takes, then there’s no need to reach out to the customer. There’s no need to work through other data providers that will give you corporate registry information, etc.
There’s one standard, one go to, and that utility would be public source information from corporate registries, for example, but also any additional documentation that clients perhaps don’t keep up to date on those third-party vendors’ sites or in public registries or whatever or anything you need to validate or verify that information. So, from a bank’s perspective, as a one-stop shop to go to where you’ve got a nicely packaged up folder of that client and they can provide it. The thing is, stuff like that hasn’t really worked. So if you onboard banks, which we do, you can go to the Swift KYC registry or you can go to Bankers Almanac. And most people don’t really keep it that up to date. We probably should. I have to be honest I don’t I’m responsible for it and I’m constantly getting chased because I’m just really bad at keeping it up to date. My view is if we’re dealing with a bank or a respondent, I want to be having that conversation with them. I don’t necessarily want to just post everything there. I want it to be a partnership, a conversation. So, it would have to be some element of obligation.
The KYC utilities, it’s not just the one in 2017. I think there have been about three attempts over the last decade to do a KYC utility, and they’ve all broken down. And I think it’s because there aren’t strongly enough aligned incentives to pay for it. So, it works for customers because then they don’t have to give their information multiple times. But banks aren’t always as fast, especially the larger institutions, because they can – they’ve got the clout to go and ask customers for their identity docs a million times over, and they know that most clients will because they need the account. So, I think the incentives are a little bit misaligned. And from what I’ve read of the one that you mentioned, it seems to be like it’s an amalgamation of information from corporate registries and it’s all third-party data that you can pretty much get online anyway or pay for. So I still don’t really understand what the benefit is unless it’s companies giving the additional information and then you’ve got data privacy and data sharing issues.
I’m a bit pessimistic probably just because I’ve been doing this for 15 years, which isn’t a super long time, but I’ve seen it fail so many times. On the TM side of things, I think the initiative in the Netherlands is super interesting, but I can’t quite yet understand if you’re monitoring across the five organisations, which is what you should be doing because money laundering takes place across organisations, are you still obligated to monitor within your organisation? Because it is a basic AML regulation that you need to monitor the transactions that pass through you. If you only have to do it intra-network, that’s great. Who’s paying for the investigators? Who’s paying for the tools? Who’s paying for the teams? Who’s aligning the data so that transactions can be read in the same way across all the organisations? And how can you investigate those transactions if, for example, one of the customers is at another bank and you don’t have that KYC file? So, there are still some things for me that need ironing out. But ultimately, if there’s one place to go for KYC and everyone has access in a controlled way and people are monitoring transactions across organisations, which is how money laundering happens, in theory, it’s a great idea. I’ve just yet to see it become practically implementable, and it will require regulators to do it.
Mélisande Mual: [00:26:07] And would it be in theory, because we talked about, we touched upon the high false positive rates, which is definitely something that needs to be solved. I mean, there are too many people involved with the false positives, could this potentially be a solution for this to basically reduce the false positives and also reduce the number of people that are working on that by basically pooling data? And I guess, also a business case in cost reduction, if you get this right.
Livia Benisty: [00:26:37] If you get it right, there’s a benefit to catching financial crime. And this is exactly it, I don’t think there’s a business incentive because I don’t think you will minimise false positives. To do that, you need to understand your business and your flows to a tee, and tailor your rules accordingly. You can’t do that across five organisations that are doing multiple different flows. You need to be so specific. And cost reduction I don’t think will take place when it comes to integrating multiple organisations’ systems and the investigators and who’s going to pay for it. I think it will be brilliant for capturing financial crime. I don’t think that there’s necessarily, unfortunately, a business incentive there.
Mélisande Mual: [00:27:19] Chris, any thoughts on this from your end or from Leslie?
Chris Caruana: [00:27:21] Yeah, I wonder have they really done or taking the steps to build that business case, right? So, if I think about when we want to go and get investment to go and deliver a product, or I want to go and get budget to implement a new technology in my control framework, I have to build the business case around that, right? I think the ideation stage is they haven’t really gotten past that, right? No-one has sort of done that homework to say, look, here’s what it’s going to cost, here’s who’s going to pay for it, here’s the standard?
So, to this point, earlier, KYC utility, kind of, what does that mean, right? Have you set the definitive this is what the KYC utility means, this is how it’s going to be accessed, this is the information that’s going to be available, these are the standards that all of us are going to follow when we access and use this information as part of our KYC obligations. Oh, and then, by the way, you also have your own individual KYC obligations that the regulatory level that’s imposed on you as well, and I’m not to say that this isn’t a step in the right direction, but there are there’s probably a tremendous amount – or there definitely is a tremendous amount – of questions that still need to be answered and aligned among the participants in some of these schemers. And they’re not there yet.
So probably a quicker route to success right now is eliminating some of the existing barriers between information sharing among institutions, right? So, we need to stand up a completely separate apparatus to do that. Not necessarily, right? In parallel, that could happen. But there are some quick wins that we should be thinking about in terms of removing data sharing restrictions, while also not compromising the likes of GDPR, obviously, and customer privacy, that should be happening quicker in parallel to, OK the longer-term play here is to stand up some sort of utility that can be leveraged by the industry in collaboration with some of the public sector, whether that’s law enforcement, whether that’s regulatory bodies. So, I think they have to put some skin in the game as well, too, from a financial perspective in order to make it an incentivised endeavour for our institutions and clients.
Mélisande Mual: [00:29:22] Yeah, you refer to basically impediments of data sharing, but within an organisation or outside an organisation, are you referring to, is that primarily GDPR or are there other restrictions as well?
Chris Caruana: [00:29:34] Just think about it systematically think about it from a privacy perspective. That’s a whole exploration. It’s a whole other topic all of itself for sure, is what are some of those hurdles to sharing information across organisations, right? You can come at it from multiple different angles, but I fear that we would run into next week.
Livia Benisty: [00:29:52] We talk about GDPR and data privacy a lot, but even in a large international bank and I know this first-hand, the US, I would have names added to a blacklist that my team had to screen against in Europe. That name was put on the blacklist in New York. I have no idea why. I have no details. I don’t know if we filed a SAR. I don’t know if there was a public news source. And when I reached out to the New York team as to why, when I’ve got a hit on it, they’re not allowed to tell me and that’s just tipping off. So if even within the AML law, we’re already stopping the provision of information and then you’re going to add data privacy legislation on top of it, which doesn’t quite match, I think that we’re almost cutting off our nose to spite our face of it. We’re our own worst enemy in some ways.
Mélisande Mual: [00:30:30] We were in the experience of having to go through this as well by opening up some bank accounts, I could also wonder why doesn’t the bank ask the customer if they would give consent to share their data within the network of the bank. If it’s not allowed, you could ask for consent because it’s in the interest as well of customers, SMEs to get onboarded or to speed up the process.
Chris Caruana: [00:30:55] That goes back to that business enablement piece that we’re talking about. So, you have that risk information already sitting there within your bank with a simple customer consent. It can be leveraged somewhere else within that same multinational organisation.
Mélisande Mual: [00:31:09] Yes. Thank you. There is one last question. It’s also about the data sharing initiatives, routes or rules similar to access to account in PSD2 accompanied with a standardised form of sharing account data, aiding in combating AML, perhaps via a joint venture to specialise in detecting money laundering, possibly with the use of AML or machine learning, or that companies with suspicious customers need to notify the bank. So the responsibility does not rest only on one party.
Livia Benisty: [00:31:42] I think it’s an interesting concept. It’s one I was to be fair more involved in looking into actually at BBVA when I was in the open banking arm. So, anything I say, I want to caveat that it could be quite out of date. It is definitely an interesting thought about how we can authenticate requests for information. So, at the moment you can use that to authenticate your request for the static situation of an account and how much money is in and out and certain features of it, but not necessarily to request the KYC behind it, which I think is the question.
So, could you use that to authenticate your request for the due diligence behind an account? I think it’s an interesting idea. I think that we get into a new argument around data privacy. Much the same thing with digital ID like the key thing that needs to be solved is the authentication and the secrecy and privacy element. But I think it’s an interesting idea.
Russell Goldsmith: [00:32:32] Well, that’s it for this episode of the Knowledge Circle podcast. Thanks once again to our guests, Livia Benisty, Chris Caruana and Antonia Michail and to Mélisande for hosting. I hope you enjoyed the conversation and, if you did, please follow, like and share on your podcast platform of choice. Hope you can join us on the next episode. Until then, thanks for listening and goodbye.