FINTRAIL Book Club: Anti-racism

In October 2020, and to mark Black History Month, FINTRAIL ran a team book club dedicated to reading books authored by Black, Asian, Minority Ethnic and Inidigenous people and People of Colour (BAME and BIPOC). We did this to improve our understanding of racism and the issues faced by the BAME/BIPOC communities, as well as to facilitate an open discussion, ensuring that everyone in the team participated actively in a discussion about racism. We wanted to share how we set up the book club, our key takeaways and our next steps.

We devised a list of books by BAME and BIPOC authors, and asked each person in the team to pick one book to read. We asked a series of short, generic questions (what was the story, what did you learn, what challenged you about the book) and then all met (virtually of course in these COVID-19 times) and each ran through the book we’d read and answered the three general questions.  This meant everyone could share their individual take on the book they’d read and we got to learn about a wider range of books than if we’d simply picked one book for us all to read. The team at FINTRAIL offers a huge note of thanks to Meredith and Ishima for coordinating all of this.

We held a lively and engaging discussion, the main takeaway being that we all experienced an overwhelming feeling of shock and frankly horror at the injustices BAME and BIPOC individuals have faced on a continuous basis throughout history. We learned from Mikey’s reading of “In Black and White” [Alexandra Wilson] about the injustices faced by black criminal barristers in the UK, and how the mistreatment of black people in the legal profession - often mistaking them for defendants - negatively impacts how justice is served to our BAME populations in the UK. There is a horrible and unjust (pun fully intended) irony here. Meredith read “Indian Horse” [Richard Wagamese], centering on the author’s experiences as an Indigenous person in Canada of the residential care system. The practice of residential care for indigenous people was only disbanded in the 1960s in Canada, and it subjected indigenous children to religious cleansing, child labour and sexual abuse in many cases, turning on its head the notion that Canada has been sensitive in its handling of indigenous communities. 

We observed too that there were wild discrepancies between how much black history we had all covered at school; some colleagues had covered elements of black history in detail, whereas others hadn’t touched on anything specific.  For many of us, this discussion was one of the first opportunities we’d had (or taken) to discuss racism openly and learn about black history.  That all being said, and as Maya pointed out based on her reading of “Black and British” [David Olusoga], it became clear to us that we need to start teaching black history not as a history of black people in Britain, but as an integral part of the history of Britain. We lose important context if we do the former. As such, it seems critical that schools and educational institutions examine urgently how they are teaching history that fully encompasses the Black, Asian and Minority Ethnic/BIPOC experience. 

As regards other practical steps to be taken, we learned from James’s reading of “Why I’m No Longer Talking To White People About Race” [Reni Eddo-Lodge] that the need for black equality is not about inverting the power balance between black and white people, but rather rebalancing that power evenly. James noted - in a work-based example - that the notion therefore of hiring people solely on “merit” was no longer sustainable, and that to redress the imbalances caused by racism, more proactive hiring of BAME/BIPOC individuals is needed.  

Finally, we learned from a number of the books we read that white people have been conditioned not to talk about race, or deal with their privilege and that this has to change if we are to make inroads into the battle against racism. Therefore, a small, but important logistical observation stood out: running the book club the way we did - with each person reading and commenting on a different book -  facilitated a very open discussion.  In turn, this ensured that everyone participated and had to start that conversation about white privilege and Black, Asian and Minority Ethinc/BIPOC oppression with the group, and - most importantly - with themselves.

If you’d like to learn more, please contact Gemma Rogers, Co-Founder, or email us at: contact@fintrail.co.uk.

Active Anti-Racism in Anti-Financial Crime: Our Next Steps for Combatting Discrimination

At FINTRAIL, our US and global teams have been closely watching the swell of protests unfolding in response to the shocking deaths of George Floyd and Breonna Taylor - the latest victims of ongoing and unjustifiable police brutality against black people. However, racism isn’t just the existence of bad actors engaging in criminal acts of violence; police brutality emerges from systematic and deep-rooted racism that has infected justice systems in the US and around the world for centuries. And unfortunately, the anti-financial crime sector, integral for feeding information on suspected money launderers and terrorist financiers to police, has been complicit in this institutional racism. At FINTRAIL, we are constantly working to do more to promote diversity within our ranks and to support and learn from black voices. But we can do more as a firm to not just avoid racism but actively reject it, particularly through our work supporting anti-financial crime teams. Together, as consultants and as community leaders in the FinTech FinCrime Exchange (FFE), we can help make meaningful change to improve the treatment of black customers and to hold ourselves accountable when we get it wrong. 

1. We promise to help champion and support non-white perspectives within our own team and the teams we work with. Implicit biases exist not only in day-to-day anti-financial crime activity, but also in senior level decision-making. People can unfortunately be prone to ignoring or undermining opinions given by black people in the room - and this is even more so the case for black women. In the worst cases - the room may be entirely white, eliminating the chance for non-white voices and perspectives to influence decisions on financial crime. How else can we be held accountable and understand the impact of our processes and decisions across all areas of financial crime risk management without ensuring black people are involved in the work and have the space to make constructive challenges? Thus, as FINTRAIL, we will make sure that we use our privilege to ensure there is always diversity in the room and that we listen to any and all challenges to our approach, especially from black people.

2. We promise to work with clients to take extreme caution in the consideration of demographic factors when evaluating customer risk.  Firms building out their customer risk assessment (CRA) models may choose to include demographic factors, including nationality. While under very specific circumstances, demographics may be strongly correlated with risk (e.g. cheaply purchased nationalities), we will not advise or support the inclusion of demographic risk factors into a CRA methodology in a way that could unfairly lead to the application of enhanced due diligence (EDD) measures to a customer solely based on their racial, ethnic or socioeconomic background. In practice, this means strongly questioning whether such a factor is necessary in a CRA model in the first place and, if included, ensuring that only specific risks to the business are targeted and that there is no undue bias in the weighting of such a risk factor.

3. We promise to be aware of racial biases that may exist within ourselves and our clients when it comes to clearing and investigating screening or monitoring alerts. Even when demographic factors have not been included in the calculation of a customer’s risk, racial biases can still cloud our judgment when evaluating one customer’s financial activity versus another’s. It is well documented that people are prone to more negative perceptions of those with darker skin, often without even realizing they are doing it. This can have dangerous effects for a customer, leading to their account being frozen or offboarded and their activity being reported to police. To help mitigate implicit and explicit bias in alert clearing, we will seek to support internal and external anti-racism bias training in the context of alert clearance and will push for the provision of clear decision trees to help analysts more objectively work through potential suspicious activity.

4. We promise to do more to recognise and help mitigate the racial biases that can exist within European and American identity verification RegTech platforms. Within the US and Europe, we are really lucky to have a variety of robust identity verification tools to suggest to our clients that help automate the onboarding process. Innovative solutions allow for FinTechs to match customer selfies, live selfies or videos to a verified ID document - allowing them to onboard the customer within only a couple minutes. However, some solutions can struggle with non-white faces as their facial recognition technology hasn’t been adequately trained in correctly matching non-white faces to IDs. This can lead to serious negative consequences - non-white victims of identity fraud may have their documents stolen and used to open financial accounts without being spotted, or alternatively, genuine customers may be routed through a laborious manual review process simply because they aren’t white. We will work closely with FinTechs and RegTechs in the community to identify practical solutions to ensure that identity verification tools can more effectively verify non-white customers.

5. We promise to take more initiative to build out innovative onboarding solutions for non-standard non-face-to-face situations. Under some circumstances, customers may not have the typical documentation needed to onboard - they may not have a passport or driving licence, or they may have recently moved country and have no address history. The good news is that more and more regulators expect financial institutions to have onboarding processes in place for customers who may be unable to provide traditional documentation - though some regulators go farther than others in their guidance. The bad news is that, in the absence of meaningful guidance, firms may end up with extremely manual onboarding processes, which require robust sensitivity training for front-line staff and which can delay financial access for those most in need of it. Some firms may even inadvertently avoid establishing a written approach to non-standard identity verification cases. We will do more to work with clients to help them establish more innovative approaches to non-standard onboarding and ensure that the approach is well-documented and that necessary training has been given to the front-line.

By working with the community on these practical steps, we hope to help inspire greater change within anti-financial crime best practice. No one should have a worse banking experience or be treated as a criminal solely based on the color of their skin, and we are committed to actively fighting for an actively anti-racist approach to financial crime.