ACFCS Member Spotlight: For Quantifind’s Graham Bailey, success across 30-year career journey defined by courage to conquer data challenges, charisma to enlist human partners in public, private circles

By Brian Monroe
bmonroe@acfcs.org
Nov. 13, 2023

For more than 30 years, Graham Bailey has made a career out of bringing structure, stratification and order to the unwieldy, subjective and ever-mercurial concept of risk – first in the government, then for bank fincrime fighters.

To say that his current position as Chief Operating Officer at AI-infused risk technology pioneer, Quantifind, is a perfect fit is an understatement. Bailey has found a company to make the most out of his unique and desirous data divination skillset – and courage.

Whether it was a disruption, data-sharing and results-focused startup, as he did with Searchspace, or taking on the surveillance, risk-ranking and regulatory reporting challenges of a large international bank, as he did with Wells Fargo, Bailey has cut his teeth taking on the fincrime compliance projects that would make others quake.

His career has been working toward what many consider the Holy Grail of the fincrime fight: a system tuned by machine learning maestros, seeing the world through the eyes of law enforcement and sensitized to examiner enforcement trends with the awesome power to review structured and unstructured data in and out of the bank.

The pollyannish goal: take some of the subjectivity of human decision-making out of the equation and present the anti-money laundering or fraud analyst with a richer, more relevant case ready to be investigated – rather than a sea of alerts that simply eat up resources.

Beginning with a stronger case also gives banks a chance to use sparse investigative resources to better unravel more complex laundering syndicates.

“Financial criminals continually evolve their tactics to exploit vulnerabilities in systems and processes,” Bailey said. “The increasing sophistication of techniques, including cyberattacks, money laundering, and fraud, makes it challenging for institutions to keep pace and detect new forms of criminal behavior.”

But Bailey is cognizant you can’t be an army of one.

Some of his greatest successes, even early on at Searchspace, came from forging partnerships across banking groups in multiple jurisdictions, being able to follow the money when criminal groups jump from bank to bank – hoping individual institutions can’t put all the pieces together.

“With the globalization of financial markets, criminals exploit the interconnected nature of the global economy,” Bailey said. “Cross-border transactions provide opportunities for money laundering, making it difficult to trace and prevent illicit financial flows. Coordinating efforts across jurisdictions becomes crucial but is often hindered by legal and regulatory complexities.”

Bailey also worked closely with law enforcement – the ostensible customers of bank compliance efforts and reports of suspicious activity – knowing they could see trends before a given bank might.

In such an environment, ego is one data point that isn’t part of the equation.

To be successful in battling such a creative adversary don’t be afraid to “ask people for help,” Bailey said.

“On the whole people love to help people,” he said. “I have found that you can rarely achieve anything on your own, you need support and bringing multiple minds and voices to a problem delivers a stronger result.”

In just over a year after he started at the bank – a longtime incubator of innovation when it comes to fighting all forms of financial crime – he jumped into a top analytics post and just a few years later added Global Head of Anti-Bribery and Corruption to his title as well.

Over roughly the next decade and in parallel to leading Financial Crime Analytics, Graham oversaw a tricky merger with Wachovia and tackled oversight of what many regulators dubbed higher risk industries, establishing the bank’s Integrated Customer Due Diligence center of excellence for Money Service Businesses, Credit Investigation and Due Diligence Investigations in 2010.

On his watch to better counter those gripped by graft, Bailey set up and led Wells Fargo’s Anti Bribery and Corruption Program and even bridged the seemingly eternal divide between fraud and AML teams by spearheading the creation of the company’s Internal Fraud Analytics Group.

He also didn’t shy away from confronting the yawing maw of the data beast, delving into projects large and small – whether in due diligence, risk ranking, monitoring, investigations and reporting – and the complex, arcane backend methodologies of model risk management.  

Let’s recap that point for a moment. Yes, you read that right.

Even as regulators pushed fincrime compliance teams to develop more and more sophisticated systems, algorithms and AI-empowered technologies to fight financial crime, they then turned around to grill these same banks on the accuracy and adequacy of the models they used to calibrate risk.

So that means results were nice, but fincrime compliance teams also had to prove that the risk ranking models were stout, transparent and did what they advertised.

Think back to those painful times in algebra where you had to “show your work.”

Federal examiners did not let banks off the hook by saying the model “in the black box” is working just fine. They also weren’t too pleased with the response, “well, just ask the vendor.”

No problem for Bailey, he simply added that job to his title at Wells Fargo as well, as the Model Risk Officer for Operational Risk, Compliance and Financial Crimes.

But it was the battle scars in such a crucible that helped Bailey augment his overall knowledge of the fincrime fray, acting and reacting, adjusting and adapting as criminals shift and probe, always looking for the weakest link in bank defenses.

“We have moved from looking at statistically unusual activity to suspicious activity and counterparts of interest,” he said. “The criminal is like the zebra in the center of the heard of zebras, they are trying to avoid being noticed at the extremes so our focus needs to recognize that criminals cheat the system, so look where a cheat would be.”

In his work at Quantifind, he has gone from strength to strength, with the company having a deep bench of experience in “extracting meaning from unstructured data,” with applications in defense and government and then jumping into finding and following the tainted finances of threat actors. 

Since its founding in 2009 by quantum physicists, the company has racked up patents and top tier banking partners by pushing the boundaries of what is possible, “building machine learning technology to discover meaningful patterns across large, disparate, unstructured datasets.”

With his understanding of compliance systems, law enforcement needs and regulatory pain points, Bailey has complemented Quantifind’s team well, for the past two years working with teams in the public and private sector to break new ground in AI-enabled open-source decision intelligence.

To move the industry forward, fincrime fighters must be equal parts analysis and action, he said.

In fact, one of the worst pieces of advice he ever got was to “stop worrying about it,” an ironic axiom in the risk-averse world of compliance. “I do believe that if you have time to worry, you have time to act.”

“Being concerned with a risk or issue is something as risk professionals we always have in our daily routine,” Bailey said. “The answer though is not to worry about it but to determine the potential outcomes and the potential mitigants or resolutions.”

Bailey was kind enough to share some of his knowledge and insight in our latest ACFCS Member Spotlight:

What is one thing – either industry-related or not – that you learned in the past month?

The need for speed continues to increase. Global events continue to demonstrate the need to have speed within a financial crimes program in making a decision and driving action.

We have seen with the events in Israel the need to rapidly understand and act on illicit funding of terrorist activities.

What is something about you that not many people know?

I have coached women’s sports throughout my life. In addition to competing in many sports myself I have coached women’s rowing, women’s soccer and women’s triathlon.

It has taught me to never underestimate anyone’s ability to learn, adapt and drive for results.

All of us have potential and sometimes we just need that supporter to aid us through the tough days to enable each of us to reach our potential. Individuals are typically their own hardest critic and we all need a few supporters to enable success.

What do you do in your current role?

My current role is Chief Operating Officer for Quantifind. In this I support four of our key people focused roles.

Those teams are Sales, Marketing, Customer Success and People functions. I operate on three main dimensions: Ethics, Operational Performance and Customer Success.

Ethics covers the range of problems we look to tackle, whether those are customer challenges such as Human Trafficking risk or how we support Maternity and Paternity leave.

Operational Performance aligns the right resources to the company goals we have for delivery and growth. Customer Success is ensuring we support rapid risk identification and mitigation with AI and automation that delivers real value with the employee in the loop.

What does your career trajectory in financial crime look like?

I started as a statistician for the Ministry of Defence, United Kingdom, more than 30 years ago. I worked in analytical risk roles starting on NATO weapon systems for the Royal Navy.

I transitioned to working on Risk projects for Natwest Group that evolved to be Royal Bank of Scotland.

I then moved to be one of the initial members of Searchspace, an AI company we grew to monitor Financial Crime and Market Surveillance.

WE provided groundbreaking transaction monitoring approaches for top banks globally across Europe, Africa and post 9/11, the U.S. to combat money laundering.

What is the best advice you have ever received?

Ask people for help. On the whole people love to help people. I have found that you can rarely achieve anything on your own, you need support and bringing multiple minds and voices to a problem delivers a stronger result.

What is the worst advice you have ever received?

I think the worst advice I have ever got is “stop worrying about it.” I do believe if you have time to worry, you have time to act.

Being concerned with a risk or issue is something as risk professionals we always have in our daily routine. The answer though is not to worry about it but to determine the potential outcomes and the potential mitigants or resolutions.

What would you say are the most important attributes for someone in your role to be able to succeed?

Listening. Plain and simple. And if you multi-task when you're listening, be honest with yourself you're not listening. It happens but don’t make a habit of it.

How has (compliance, investigations, etc.) changed and evolved during your career?

We have moved from looking at statistically unusual activity to suspicious activity and counterparts of interest. The criminal is like the zebra in the center of the heard of zebras, they are trying to avoid being noticed at the extremes so our focus needs to recognize that criminals cheat the system, so look where a cheat would be.

What do you see as the key challenges related to financial crime in the sector overall?

Financial crime poses significant challenges to the stability and integrity of financial systems worldwide.

Some key challenges I’ve heard from clients include:

1. Sophistication of Criminal Tactics:

Financial criminals continually evolve their tactics to exploit vulnerabilities in systems and processes.

The increasing sophistication of techniques, including cyberattacks, money laundering, and fraud, makes it challenging for institutions to keep pace and detect new forms of criminal behavior.

2. Globalization and Cross-Border Transactions:

With the globalization of financial markets, criminals exploit the interconnected nature of the global economy.

Cross-border transactions provide opportunities for money laundering, making it difficult to trace and prevent illicit financial flows. Coordinating efforts across jurisdictions becomes crucial, but is often hindered by legal and regulatory complexities.

3. Technological Challenges:

The rapid adoption of technology in the financial industry introduces new challenges.

Cybercrime, including hacking, phishing, and ransomware attacks, poses a significant threat. Financial institutions need to continually invest in cybersecurity measures to protect sensitive data and systems.

4. Regulatory Compliance Burden:

Financial institutions operate in a highly regulated environment. Meeting compliance requirements is crucial, but the complexity and volume of regulations can be overwhelming.

Striking a balance between compliance and operational efficiency is a constant challenge, particularly for institutions with a global presence subject to diverse regulatory frameworks

5. Insider Threats:

Insiders with access to sensitive information can pose a significant risk. Whether through collusion, negligence, or malicious intent, employees within financial institutions can facilitate financial crimes. Mitigating insider threats requires robust internal controls and monitoring systems.

6. Cryptocurrencies and Anonymity:

The rise of cryptocurrencies introduces new challenges for tracking and preventing financial crime.

Cryptocurrencies can provide a level of anonymity that traditional financial transactions do not, making it attractive to criminals for money laundering and other illicit activities.

7. Data Management and Privacy Concerns:

Effective financial crime prevention relies on robust data analysis. However, the vast amounts of data generated and the need to share information for collaborative efforts raise concerns about data privacy.

Balancing effective data management and respecting privacy regulations is an ongoing challenge.

8. Resource Constraints:

Many organizations, especially smaller ones, may face resource constraints in terms of personnel, technology, and funding. This can limit their ability to implement and maintain sophisticated anti-financial crime measures.

9. Emerging Risks and Vulnerabilities:

The financial landscape is dynamic, with new products, services, and technologies continually emerging. Each innovation introduces potential vulnerabilities that criminals may exploit before preventive measures can catch up.

10. Collaboration and Information Sharing:

Collaboration and information sharing among financial institutions, regulatory bodies, and law enforcement agencies are critical for effective financial crime prevention.

However, legal, cultural, and competitive barriers can hinder the seamless exchange of information.

Financial institutions must stay vigilant and continually enhance their anti-financial crime strategies to protect themselves and the broader financial ecosystem.

How did you get your first job in the field and what advice would you give other job seekers to help land their first position?

I got my first job as part of my initial undergraduate degree program. I also did my master’s degree part time while working at Natwest.

I strongly suggest looking to get practical experience and academic experience in parallel. It enables you to apply what you learn and learn how to flex theory to real world challenges.

What is the most rewarding part of your job?

Seeing people succeed and seeing us identifying bad actors.

For professionals with 5-10 years of experience, what advice would you give to help them rise in their careers to the next level?

Go back to education in parallel to work. It provides new perspectives and new networks.

Why did you join ACFCS and/or become CFCS-certified?

ACFCS provides an ability to understand multiple perspectives from law enforcement, government, financial institutions and academia.