Series 1: AI Risk · Post 4 of 4
The AML question AI tools have not answered
A UK accountant carries a personal duty to report suspicion. Now put an AI tool between you and the source of funds documents. If an injected or doctored file shapes an AML conclusion, the suspicion you were required to form never forms. The regulation still points at you. The software points at nothing.
We have covered the PI insurer who never asked the right question, the document that quietly tells the AI what to do, and the tool that reads a hostile file without blinking. This last one sits underneath all of them.
If you are a UK accountant, you carry a personal duty to report suspicion. Not your firm's duty, yours. The Money Laundering Regulations put the obligation on the human who saw the thing and chose what to do about it.
Now let's put an AI tool in the middle of that. A client sends through source of funds documents during onboarding. The AI reads them, pulls the figures, writes a tidy summary, and the picture it paints looks clean. You read the summary, not the forty pages behind it. You sign off.
But what if one of those documents was built to be read by the model, not by you? A line it was never meant to question. A figure that doesn't reconcile, smoothed over in the summary because the tool had no reason to doubt what it was handed.
The suspicion you were legally required to form never formed. Not because you missed it, but because something stood between you and the evidence, and it didn't flag.
That is the bit the AI tools have not answered. When an injected or doctored document shapes an AML conclusion, who raises the suspicion? The regulation still points at you. The software points at nothing.
This is the whole reason Lexendo refuses to guess. Every figure traces back to its source, and when something doesn't hold up, it says so rather than tidying it away. The human stays the one who decides, and they just get to see what they are deciding on.
This is Post 4 of Series 1 (AI Risk) in The AI Footnote, my weekly note on AI in UK accountancy.
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