The Evolution of AI in Financial Crimes: From 1993’s Neural Networks to Today’s Enhanced Due Diligence
In 1993, a groundbreaking step was taken in the realm of financial crime prevention—the introduction of neural networks for fraud detection. This marked the beginning of artificial intelligence (AI) in financial crime mitigation, setting the stage for the future of compliance and regulatory frameworks. One of the most notable implementations during this time was the Financial Crimes Enforcement Network (FinCEN) Artificial Intelligence System (FAIS), which became one of the earliest AI systems designed to detect financial crimes through sophisticated pattern recognition [1]. FinCEN’s FAIS and the Role of Neural Networks FAIS was revolutionary in its use of neural networks—computer systems modeled after the human brain’s structure and functioning. By mimicking human learning processes, FAIS analyzed vast amounts of transactional data, uncovering hidden patterns that manual reviews couldn’t detect. This allowed it to pinpoint unusual activities that could signal money laundering, fraud, or other financial crimes [2]. The introduction of FAIS demonstrated how AI could be used to augment human capabilities, handling large datasets quickly and identifying anomalies that would otherwise go unnoticed. Neural networks brought about a new level of sophistication to fraud detection, evolving from traditional rule-based systems that relied on predefined scenarios to dynamic models that continuously learned and adapted. This adaptability became key in financial crime prevention, given the evolving nature of fraudulent schemes. The neural network approach of FAIS essentially laid the foundation for today’s more advanced AI tools, which are now critical in protecting the financial system [3]. AI’s Gravitation Towards Financial Crimes Since the inception of FAIS, AI has only deepened its roots in the financial sector, particularly in combating fraud and financial crimes. The need for efficiency and accuracy in compliance processes, coupled with the sheer volume of financial transactions occurring globally, has pushed institutions to adopt AI-powered solutions. AI’s ability to process and analyze vast amounts of data in real-time has become an indispensable tool for organizations seeking to mitigate financial risks while maintaining regulatory compliance [4]. Financial institutions today employ machine learning (ML) algorithms, predictive analytics, and AI-driven models that are far more advanced than FAIS. These systems not only detect fraud but also anticipate and prevent potential risks before they escalate. AI systems can now flag suspicious behavior, trace illicit transactions across borders, and identify patterns indicative of criminal activity in ways that were unimaginable just a few decades ago [5]. The Impact of AI on Compliance and Enhanced Due Diligence (EDD) One of the most significant shifts AI has brought to financial crime prevention is its impact on compliance. Compliance departments, historically bogged down by manual reviews and data-intensive processes, have found a powerful ally in AI. By automating tasks such as transaction monitoring, customer risk profiling, and regulatory reporting, AI has not only enhanced accuracy but also reduced the time needed to meet compliance requirements [6]. This shift is especially evident in Enhanced Due Diligence (EDD), a more in-depth investigation process typically applied to high-risk clients or transactions. EDD requires a granular examination of financial records, ownership structures, and potential ties to illicit activities, which can be labor-intensive. AI has transformed EDD by automating the collection and analysis of data from various sources, including public records, news reports, and social media. It can identify red flags and create comprehensive risk profiles much faster than any human team could [7]. Moreover, AI’s real-time monitoring capabilities allow institutions to maintain continuous oversight of their high-risk clients, rather than relying solely on periodic reviews. This ability to detect evolving risks on an ongoing basis has become crucial in the current global regulatory environment, where non-compliance can result in hefty fines and reputational damage [8]. The Future of AI in Financial Crime Prevention As AI continues to evolve, so too will its role in combating financial crimes. The technology is becoming more accessible and widespread, enabling even smaller financial institutions to leverage its capabilities. Meanwhile, regulators are recognizing the importance of AI in maintaining the integrity of the financial system and are incorporating guidelines for its use in anti-money laundering (AML) and know your customer (KYC) compliance [9]. One area where AI is poised to have an even greater impact is in predictive analytics. By analyzing historical data, AI can predict future risks and trends, allowing financial institutions to take preemptive measures against emerging threats. This will be especially valuable as cybercrime and sophisticated financial fraud schemes continue to rise globally [10]. Conclusion What began with FAIS in 1993 has evolved into a robust ecosystem of AI-driven solutions designed to protect the financial system from fraud and criminal activity. Neural networks were the foundation of this transformation, but today, AI has grown far beyond its original scope. Its role in enhancing compliance, especially through processes like EDD, highlights its indispensable place in modern financial institutions. As AI continues to develop, it will likely remain a cornerstone of the financial industry’s defense against crime, enabling organizations to detect, prevent, and respond to threats in ways that are faster, more accurate, and more efficient than ever before. [1]: Financial Crimes Enforcement Network (FinCEN). (1993). FinCEN Artificial Intelligence System (FAIS) documentation. [2]: FinCEN FAIS report, 1993. [3]: Riedel, S. (1994). “Applications of Neural Networks in Financial Crime Detection.” [4]: Deloitte. (2018). “AI in Financial Services: The Role of AI in Managing Risk and Compliance.” [5]: Ibid. [6]: PwC. (2019). “The Impact of AI on Financial Crime Compliance.” [7]: AML Research Institute. (2020). “Enhanced Due Diligence in the Age of AI.” [8]: Thomson Reuters. (2021). “Continuous Monitoring in Financial Compliance.” [9]: KPMG. (2020). “AI and the Future of AML Compliance.” [10]: Accenture. (2022). “Predictive Analytics: The Next Frontier in Financial Crime Prevention.”
Enhanced Due Diligence and the 2024 Elections: Make America Safe Again
As the 2024 elections approach, the spotlight intensifies on national security, economic policy, and safeguarding the integrity of the financial system. One crucial yet often overlooked area that ties all these together is the role of Enhanced Due Diligence (EDD). EDD is a critical process used to protect financial institutions—and, by extension, the country—from bad actors such as terrorists, organized crime syndicates, and other malign influences that seek to exploit our financial infrastructure. In a time when the stakes have never been higher, EDD represents more than just a bureaucratic mechanism—it is a frontline defense to ensure that those who pose a threat to national security are kept out of our financial systems. This conversation ties directly into the broader theme of national safety, one that resonates deeply with voters who are asking: What more can be done to protect America? Enter “MASA”—Make America Safe Again. The Role of Enhanced Due Diligence in National Security EDD is not just a regulatory hurdle; it is a cornerstone in preventing terrorist financing, money laundering, and other financial crimes. Banks and financial institutions have a responsibility under U.S. law to thoroughly investigate high-risk clients and transactions, identifying not just obvious red flags, but also subtle indicators of illicit activities. The Patriot Act, specifically, heightened these requirements post-9/11, signaling a shift in how financial institutions must conduct business in a globalized world where threats transcend borders. In the United States, EDD becomes even more critical as the country navigates geopolitical tensions, foreign influence on domestic issues, and the rise of cybercrime. The threat landscape is no longer limited to physical borders. Terrorist organizations and other criminal networks leverage digital channels, cryptocurrencies, and even shell companies to fund their operations. Each unchecked transaction can open the door for potential attacks or further entrench the influence of these bad actors. In the context of the upcoming election, this creates a policy battleground. Voters are increasingly concerned about safety—both physical and financial. They want to know how their elected officials will ensure that those with ill intent will not gain access to critical financial networks that could destabilize the economy or endanger lives. How Financial Crimes Influence Policy and Voter Sentiment Financial crimes do not exist in a vacuum. They are often the undercurrent of larger societal issues—funding terrorism, human trafficking, and drug cartels. Each time a criminal entity infiltrates the U.S. financial system, it poses a direct risk to American citizens. The consequences are multifaceted: from financing extremist organizations to destabilizing communities with illicit drugs, the ripple effects are felt far beyond Wall Street. This is why financial policy, and in particular the enforcement of robust EDD measures, plays a significant role in shaping the political landscape. Candidates who promise to tighten these regulations and bolster the tools available to regulators and financial institutions to combat bad actors will likely gain traction among voters who prioritize safety and security. Further, as financial crimes evolve, so too must policy. A proactive stance on EDD can help future-proof America’s financial system, especially in the face of emerging technologies like cryptocurrency and decentralized finance (DeFi), which bad actors increasingly exploit. The regulatory framework must keep pace with innovation to ensure that terrorists and other criminals don’t use these platforms to bypass traditional scrutiny. MASA—Make America Safe Again: A Call for Stronger Financial Security In this election cycle, the concept of “MASA”—Make America Safe Again—becomes more relevant than ever. While traditionally associated with physical security and military strength, the idea of “safety” must now extend to our financial system. Voters want to know that the institutions they trust with their money are equipped with the right tools and policies to keep criminals out. This means enforcing and expanding EDD measures to adapt to the new realities of financial crime. MASA isn’t just a campaign slogan; it’s a vision for the future. It’s about ensuring that terrorists, money launderers, and other bad actors have no place in America’s economy. It’s about protecting American citizens from the financial predators who exploit gaps in the system for their own gain. Most importantly, it’s about preserving the integrity of our financial and national security infrastructures for future generations. The Road Ahead: EDD and the Future of the Country Looking beyond the election, the future of Enhanced Due Diligence will hinge on policy decisions made now. Voters have the opportunity to elect leaders who will not only strengthen national security but also bring our financial defenses into the 21st century. By expanding the scope of EDD and leveraging new technologies like AI, America can outsmart the criminals who adapt their tactics faster than ever before. As the 2024 elections draw closer, we must ask ourselves a critical question: What kind of future do we want for America? A future where terrorists can launder money through our institutions, or one where we’ve built an impenetrable financial system, capable of thwarting even the most sophisticated criminals? Through EDD, financial institutions have the power to make a real impact. Through policy, elected officials have the power to make that impact lasting. And through their votes, the American people have the power to make America safe again—financially, socially, and globally. MASA—Make America Safe Again.
Navigating Global Complexities: Enhanced Due Diligence Across Industries and Regions
In today’s increasingly globalized and interconnected world, financial crimes are more sophisticated than ever. As a result, organizations conducting business internationally must adopt stringent compliance measures, such as Enhanced Due Diligence (EDD), to ensure they are not inadvertently aiding illegal activities like money laundering, terrorism financing, or fraud. However, the risks associated with certain industries vary dramatically by region, as do the regulations that govern due diligence requirements. The Global Landscape of Enhanced Due Diligence Enhanced Due Diligence refers to a more in-depth examination of individuals or entities that are considered high-risk, often beyond standard Know Your Customer (KYC) measures. EDD involves scrutinizing complex ownership structures, understanding the source of funds, and flagging unusual activities that might indicate financial crime. What makes EDD complex is that risks are not uniform across the globe—what might be seen as a risky industry in one country could be relatively low risk in another. Industry Risk: A Matter of Geography and Context One of the key challenges in EDD is understanding how the risk profile of industries can differ depending on the jurisdiction. For example, in some countries, the furniture industry might be seen as high risk due to its cash-intensive nature and potential for use in money laundering schemes. A prime example is the Middle East and North Africa (MENA) region, where furniture import/export can often overlap with informal economies, heightening the potential for illicit financial activities. In contrast, in the U.S. or parts of Europe, furniture stores are typically considered lower risk due to stricter regulations on cash transactions and a more transparent supply chain. Similarly, industries like real estate and luxury goods might be viewed as high-risk globally, but in countries like Switzerland or Singapore, additional scrutiny is mandated due to their prominence as financial hubs. Jewelry stores, art dealerships, and high-end real estate are subject to EDD because they are attractive avenues for laundering large sums of money in a single transaction. In contrast, the agricultural sector may be considered high risk in countries with a history of narcotics production, such as parts of Latin America, where legitimate agricultural enterprises could be used as a front for money laundering from illegal drug trade. Meanwhile, in countries like New Zealand or Denmark, agriculture is not typically associated with financial crime, and the sector may face fewer compliance requirements. Regulatory Frameworks Driving EDD Regulatory bodies worldwide have established frameworks to guide organizations in identifying and managing high-risk clients and industries. These frameworks aim to promote transparency, mitigate risk, and protect the global financial system. A few key examples include: The USA PATRIOT Act: In the U.S., the Patriot Act requires financial institutions to adopt rigorous anti-money laundering (AML) programs, including EDD when onboarding high-risk clients. For instance, a bank might be required to investigate the ultimate beneficial owner (UBO) of a corporation in a country flagged by the Financial Action Task Force (FATF) as non-compliant with AML standards. The EU’s Anti-Money Laundering Directives (AMLD): The European Union has established several directives that impose strict EDD requirements. Financial institutions must apply EDD to clients from high-risk third countries, as identified by the European Commission. For example, a real estate deal in Spain involving funds from Russia or China might prompt a more thorough investigation due to perceived risks in those regions. Asia-Pacific Region: Countries like Singapore and Hong Kong have adopted stringent AML and Counter-Terrorist Financing (CTF) regulations in line with FATF guidelines. Financial institutions must not only follow international rules but also consider local nuances, such as the high number of shell companies or complex ownership structures commonly seen in the region. These regulatory frameworks are designed to force organizations to dig deeper, looking beyond surface-level information to detect red flags that may not be apparent with standard due diligence. Complexity and Knowledge: The Heart of Enhanced Due Diligence EDD is not simply a matter of following a checklist—it requires a nuanced understanding of global political and economic contexts, as well as awareness of local customs, regulatory environments, and risk indicators. For instance, conducting EDD on a business in Eastern Europe may require an understanding of how organized crime syndicates operate, while EDD in parts of Africa may demand insight into how government corruption could influence financial flows. Moreover, the complexity of EDD is magnified when dealing with cross-border transactions or multinational companies. For example, imagine a large company headquartered in the U.K. but with subsidiaries across Southeast Asia. Understanding the web of ownership, transaction flows, and the legal environment in multiple jurisdictions is a daunting but essential task to ensure compliance. How EDD Helps Meet Regulatory Requirements Following EDD regulations ensures that organizations are taking the necessary steps to minimize exposure to risk. By deeply analyzing customers’ backgrounds, including their sources of wealth, business activities, and geographic ties, companies protect themselves from unknowingly engaging in transactions with sanctioned entities, politically exposed persons (PEPs), or other high-risk individuals. In addition to safeguarding against financial crime, adhering to EDD requirements helps organizations avoid hefty fines and legal penalties. Non-compliance can result in significant financial losses, damage to reputation, and loss of business licenses. Financial regulators worldwide, from the U.S. Office of Foreign Assets Control (OFAC) to the European Central Bank (ECB), are increasingly vigilant, issuing record-breaking fines for institutions that fail to meet EDD obligations. Conclusion: A Global Perspective for a Global Challenge Enhanced Due Diligence is a critical pillar of global compliance programs, but its successful execution requires more than a one-size-fits-all approach. Industries and regions are not uniform in their risk profiles, and regulations must be tailored to reflect the local realities and threats. Financial institutions, multinational companies, and any organization involved in global business must develop a deep understanding of the world around them—its risks, its regulations, and its opportunities. By doing so, businesses can effectively navigate the complexities of EDD and contribute to the ongoing battle against financial crime, all while staying on the right side of the law.
What is AI-Powered Enhanced Due Diligence (EDD), and How Can It Change the Game?
In today’s fast-paced digital economy, risk management and compliance have never been more critical. As businesses scale globally and regulations grow more complex, the need for effective due diligence processes has skyrocketed. Enhanced Due Diligence (EDD) goes beyond basic Know Your Customer (KYC) practices by thoroughly investigating higher-risk clients or partners. However, traditional EDD methods are often slow, resource-intensive, and prone to human error. This is where AI-powered EDD comes into play, representing a transformative approach to managing compliance and risk. What is AI-Powered EDD? AI-powered Enhanced Due Diligence leverages artificial intelligence and machine learning to automate, streamline, and enhance the thoroughness of traditional due diligence. By integrating AI into this process, organizations can analyze vast amounts of data from multiple sources in real time, making it faster and more efficient than ever before. This goes beyond merely collecting information. AI-powered systems can cross-check a broad array of data points—such as financial transactions, regulatory filings, media coverage, and social media posts—and identify patterns or anomalies that a human analyst may miss. AI can also track a merchant’s ongoing risk status by continuously monitoring changes, such as new litigation, business ventures, or even subtle signs of financial distress. How Is AI-Powered EDD Different from Traditional EDD? The primary difference between AI-powered and traditional EDD is speed, accuracy, and scalability. Traditional EDD is often conducted manually by compliance officers or analysts. They must painstakingly sift through documents, news articles, and reports, which can take days, if not weeks, to complete. Human analysis, while thorough, is subject to biases, fatigue, and occasional oversight, making it difficult to scale effectively as the volume of data grows. In contrast, AI can process vast quantities of data almost instantly and provide real-time updates. It can analyze more sources, spot hidden correlations, and even predict future risks based on historical patterns. Machine learning algorithms improve over time, learning from both successful and failed detections, making them more accurate with use. In short, AI-powered EDD eliminates the bottlenecks in traditional processes, turning what used to be a laborious task into an efficient, automated workflow. How Can AI Change the Game in EDD? AI-powered EDD is set to redefine how businesses and institutions approach risk management and compliance. Here’s how it can change the game: Faster Decision-Making: AI accelerates the time it takes to conduct thorough investigations. Compliance teams can make informed decisions faster, reducing the risk of onboarding bad actors and increasing overall operational efficiency. Improved Accuracy: AI can spot trends and anomalies across more data points than any human ever could. This improves the quality and depth of the due diligence, reducing the likelihood of overlooking critical red flags. Cost Efficiency: By automating labor-intensive parts of EDD, AI reduces the need for large teams of analysts, resulting in significant cost savings for companies. This is especially beneficial for startups and SMEs that need thorough risk assessment but lack the budget for large compliance teams. Ongoing Monitoring: Traditional EDD is a point-in-time analysis. AI, however, enables continuous monitoring. By keeping tabs on a company or individual in real time, AI can provide early warnings when risk levels change, ensuring that companies are not caught off-guard. Global Compliance: As regulations differ from one jurisdiction to another, AI-powered EDD tools can be programmed to stay up-to-date on global regulatory requirements, ensuring that organizations comply across multiple regions without manual intervention. Steps to Integrate AI into EDD Now that we understand the potential of AI-powered EDD, the question is: How do we bring AI into the fold of everyday risk management and compliance? Here are a few steps companies should consider: Invest in AI Training and Awareness: To successfully implement AI, organizations need to understand its capabilities and limitations. Invest in training for your compliance and risk teams to ensure they are comfortable working alongside AI tools. Select the Right AI Tools: Not all AI is created equal. When choosing AI-driven solutions for EDD, ensure that the software is capable of analyzing the specific types of data most relevant to your business and industry. Look for tools that offer machine learning algorithms that can improve over time. Collaboration between Humans and AI: AI should not be seen as a replacement for human analysts but rather as an enhancement. Compliance officers and risk analysts should collaborate with AI tools, using them to focus on the most critical tasks while the AI handles more routine analyses. Ongoing Auditing and Testing: AI models need to be monitored and refined over time. Ensure that your systems are regularly audited to ensure accuracy and compliance with regulatory requirements. Create a Culture of Innovation: Encourage your teams to embrace AI as a valuable tool rather than a threat. AI can free up valuable time for analysts to focus on higher-order tasks, such as strategic risk assessments or improving policy frameworks. Conclusion AI-powered Enhanced Due Diligence is more than a technological upgrade; it is a paradigm shift in how businesses manage risk and compliance. By automating repetitive tasks, improving accuracy, and enabling real-time monitoring, AI has the potential to revolutionize the way we think about due diligence. As we look ahead, companies that successfully integrate AI into their EDD workflows will not only be better prepared for regulatory changes but will also position themselves at the forefront of innovation in risk management. AI-powered EDD is no longer a futuristic concept—it’s a present-day necessity for staying competitive in the modern world. The question isn’t whether AI should be part of your world, but how soon you can make it happen.
Navigating the Landscape of KYB, KYC, CIP, CDD, and EDD: Differences, Commonalities, and the Pros & Cons
In the world of compliance, terms like KYB, KYC, CIP, CDD, and EDD are often used interchangeably, creating confusion among professionals and businesses alike. However, each of these processes serves a distinct purpose in managing financial crime risks, and understanding their differences and overlaps is crucial for crafting effective compliance strategies. This blog post unpacks the differences, commonalities, and the pros and cons of these vital components of compliance. 1. Know Your Business (KYB) What It Is: KYB is the process of verifying the identity and legitimacy of a business entity. It involves assessing the company’s ownership structure, verifying beneficial owners (those who own 25% or more of the company), and ensuring that the business is operating legally. Commonality with Others: KYB mirrors the principles of KYC, but at the entity level. Both processes aim to prevent fraud, money laundering, and the financing of terrorism by verifying identities. Pros: Risk Mitigation: By understanding the business’s structure, operations, and ownership, you mitigate the risk of financial crime, including shell companies and fraudulent entities. Regulatory Compliance: It ensures adherence to Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. Cons: Time-Consuming: KYB can be resource-heavy, especially for large corporations with complex ownership structures. Cost: Conducting thorough KYB checks, especially across multiple jurisdictions, can be expensive. 2. Know Your Customer (KYC) What It Is: KYC is the process of identifying and verifying the identity of individual customers. This includes gathering personal data, such as name, address, and ID documentation, and ensuring the information is accurate and current. Commonality with Others: KYC shares a close relationship with CIP (Customer Identification Program) and is often viewed as a broader framework that encompasses both CIP and CDD (Customer Due Diligence). Like KYB, KYC aims to verify identities but at the individual level. Pros: Trust Building: Helps financial institutions build trust with customers while ensuring they are not engaging in illegal activities. Prevents Fraud: Essential for detecting and preventing fraud or the use of false identities. Cons: Intrusive for Customers: Frequent documentation requests can lead to poor customer experience. Data Privacy Concerns: Handling and storing personal data can create privacy and security risks. 3. Customer Identification Program (CIP) What It Is: CIP is a regulatory requirement in many countries, particularly in the U.S., where financial institutions must collect specific identifying information from their customers, such as name, address, date of birth, and ID number, and verify it before opening an account. Commonality with Others: CIP is a subset of KYC and shares a significant overlap with its requirements. While KYC may include broader due diligence activities, CIP specifically focuses on the identification process and is mandatory for financial institutions in jurisdictions like the U.S. Pros: Mandatory Compliance: It helps financial institutions stay compliant with legal regulations. Straightforward: CIP has clear guidelines that are relatively easy to implement. Cons: Limited Scope: CIP only focuses on identification, leaving out more in-depth checks like transaction monitoring or understanding the customer’s financial behavior. 4. Customer Due Diligence (CDD) What It Is: CDD is a process within KYC that goes beyond identification and involves assessing the risk associated with a customer. It includes reviewing the customer’s source of funds, transaction patterns, and potential ties to high-risk industries or regions. Commonality with Others: CDD is a component of both KYC and EDD, and is required for all customers at a basic level. Like KYB, it involves verifying details, but focuses more on ongoing monitoring of customer activity. Pros: Risk-Based Approach: Helps financial institutions tailor the depth of their scrutiny based on the level of risk a customer presents. Continuous Monitoring: CDD allows for ongoing reviews, ensuring that changes in a customer’s profile are detected in real-time. Cons: Resource-Intensive: While it is critical for risk management, continuous monitoring can require significant resources. Potential for False Positives: A risk-based approach can flag innocent customers due to overly cautious systems. 5. Enhanced Due Diligence (EDD) What It Is: EDD is a deeper, more thorough investigation applied to high-risk customers, such as politically exposed persons (PEPs), businesses operating in high-risk jurisdictions, or those with complex ownership structures. EDD often includes additional verification steps, like source of wealth checks, scrutiny of transaction history, and review of media reports or other external data. Commonality with Others: EDD is a more robust form of CDD and is typically applied when KYC or CDD determines that a customer poses a higher risk. It also complements KYB when dealing with high-risk business entities. Pros: In-Depth Risk Management: EDD provides a higher level of scrutiny, making it harder for bad actors to exploit financial systems. Compliance with Global Standards: Required under AML frameworks such as FATF and is crucial for ensuring institutions meet regulatory obligations. Cons: Costly and Time-Consuming: Due to the depth of investigation, EDD can be resource-intensive, both in terms of money and time. Challenging for Customer Relations: Extensive checks can deter high-net-worth individuals or businesses from engaging with financial institutions. Conclusion In summary, KYB, KYC, CIP, CDD, and EDD are essential components of a robust compliance program, each serving a unique role in managing risk. While KYB focuses on businesses, KYC and CIP ensure the legitimacy of individual customers. CDD provides ongoing monitoring to assess customer risk, while EDD takes due diligence to the next level for high-risk clients. Choosing the right process depends on your organization’s risk appetite, regulatory obligations, and operational capacity. Balancing thorough risk assessment with customer experience is key, and understanding the nuances of each approach will help you optimize your compliance strategy. By mastering these acronyms and their applications, financial institutions can foster a secure, compliant, and customer-friendly environment, paving the way for growth in an increasingly regulated world.