Joining me today is Ilham Tamimi, Senior Compliance, Financial Crime and Governance Executive with 30 years at Citigroup, HSBC, First Abu Dhabi Bank, and Zand Bank. Ilham, welcome back.
Thank you so much. Thanks for having me, Rachel.
After nearly three decades in global banking, financial crime compliance, and digital assets regulation — what made now the right moment to launch FinEthica Advisory and where did you see the gap?
It took almost a decade from the seed idea of FinEthica Advisory to where it is today. There was never a very right time to make the first step. FinEthica Advisory has been live in the UAE market, serving the UAE, GCC, and clients in the UK since January this year. We are specialised in compliance and governance — regulatory compliance, financial crime compliance, governance and risk — both for conventional financial institutions and for fintechs and VASPs. At FinEthica Advisory, we are really focused on making compliance easy, agile, and lean. Compliance does not have to be scary. It does not have to be a roadblock. After so many decades, I still see the industry viewing compliance as only about regulations — sometimes the function that makes things harder. However, compliance done well and done right opens a land of opportunities for making businesses more profitable and more consciously established. That is what we are aiming at with FinEthica Advisory.
FinEthica Advisory combines finance, technology, and ethics. When you are advising a board or a CEO, how do you actually describe what ethical means?
We try to keep things simple — less is more. Three major things. The first test: whatever decisions you are making today, if those decisions went public tomorrow or landed on a regulator's desk, would you be comfortable talking about them? That is test number one for boards. The second thing: is it really enough to do the minimum requirement? Minimum requirements set the floor, not the ceiling. It is always good to focus on what exactly is needed rather than just the bare minimum. We encourage them to strike the right balance. And the third is about culture — because at the end of the day, culture is what governs everything and impacts everything. We try to help them set the right culture for their ongoing operations.
AI is now screening transactions, writing suspicious activity narratives, and monitoring wallets. At which point does the compliance officer stop being accountable and become merely a passenger?
When a compliance officer becomes a passenger is when they cannot fully explain what the AI is working on. That is rule number one. Any compliance officer or anyone who deploys AI has to do it responsibly — starting with being 100% aware of what the AI is designed to do, how it works, what data it uses, and what controls are in place. Leaving financial crime decisions to the machine is not possible today. It is not yet there. There is a new profession emerging globally: certified AI governance and ethics experts. Major universities have launched certification programmes. I had the privilege of completing one earlier this year as part of the first cohort at Oxford Saïd Business School. We try to help companies build responsible AI trails and responsible AI adoption by working through their AI governance policies. We have also built an alliance with academia, with an academic advisor within the company, where we are starting a white paper series on AI deployment in finance and compliance.
Is it really just about having the underlying knowledge of how the AI reached its decision?
Absolutely — having that knowledge is critical because without it you cannot judge, and you cannot direct AI to work properly. The decisions made in a financial crime compliance function — filing suspicious activity reports on individuals and companies, sometimes freezing accounts or transactions — have direct impact on the livelihood of people. Compliance is not a policing function. We can only show what the data entails and what is the right thing to do. The decision making sits with the authorities that compliance reports into. But if you report the wrong thing, you have an important role in impacting someone's life in a negative way. That is a huge responsibility and accountability. That is why when it comes to AI deployment, I want everyone to be genuinely aware of what they are prompting and what they are implementing AI for. It requires real accountability and responsibility.
Thank you so much for joining us today.
Thank you so much for having me, Rachel. It has been a great pleasure.
