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Boomer’s Blueprint: Attributes of an ‘Exponential Organization’

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Approximately eight years ago, I learned about “Exponential Organizations” while attending Abundance 360, an annual conference organized by Peter Diamandis, author of “Abundance,” founder of X-Prize, and co-founder of Singularity University. Dan Sullivan’s Strategic Coach team, with conference experience, helped with the organization. That conference has grown tremendously over the years and provided insights into the convergence of various technologies, especially the future framework for organizations, including CPA firms. I have always looked outside the CPA profession for trends that will improve our profession.

Open ExO is relevant to CPA firms and their best clients. (I will explain in more detail about best clients later.) At Boomer, we have integrated much of the ExO framework into our consulting practice and Boomer Circles over the past eight years. This year, I decided to get serious and became certified as an ExO consultant. These attributes align with Boomer Consulting’s leadership, talent, technology, process and growth pillars. Let me assure you that becoming an ExO requires a unique-ability team. One individual does not have all the skills. That is true at Boomer and at your CPA firm. It is a team sport!

As CPA firms navigate an increasingly complex and competitive landscape, the need for scalable, efficient and innovative approaches to growth has never been clearer. Enter the concept of the “Exponential Organization” — a framework developed to help businesses achieve tenfold growth by leveraging modern technology and strategic principles. For CPA firms, adopting ExO attributes isn’t just a way to boost profits; it’s a pathway to attract top-tier talent and engage clients looking for forward-thinking solutions.

The ExO framework comprises 11 key elements designed to create a sustainable, high-growth environment. While each attribute is unique, they collectively build a powerful, adaptable infrastructure that can position CPA firms and their best clients for long-term success. Over the past eight years, I presented the concept to numerous firms and immediately the resistance came from within firms about how they didn’t want to be “10x” and they could not find the talent. This is part of the firm immune system that resists change.

Change the question and the ExO framework immediately becomes relevant. How do firms add 10x value to their best clients? Many firms focus too little on their top 20% of clients (who produce 80% of their revenue) and spend too much time on the other 80%. Focus on the top 20% and transformation utilizing the ExO framework serves as an inspirational and guiding roadmap. The good news is that most firms only need to focus on three or four of the attributes to transform, while startups need to focus on all the attributes.

Defining the ‘why’

At the heart of any Exponential Organization is its “massive transformative purpose” — a compelling reason for existing that goes beyond profits. For CPA firms, an MTP could be “Designing firms and their clients for success in the 21st century and beyond.”

An MTP serves as a guiding star for the firm, aligning team members, processes and services with a shared vision. This clarity of purpose is a magnetic force for talent, especially for young professionals seeking meaningful work in values-driven environments. When clients see a firm operating with purpose, it builds trust, strengthens relationships, and differentiates the firm in a crowded marketplace. Once you have defined your MTP, the attributes accelerate the execution of your vision.

1. Staff on demand: Flexibility with high-quality freelance talent. Traditional CPA firms often carry fixed overhead in the form of full-time staff. However, by incorporating a “staff on demand” model, firms can leverage a network of skilled freelancers and contractors for specific projects, allowing flexibility and cost efficiency.

Engaging external experts can reduce payroll costs, especially during off-peak seasons, and attract niche talent without the full-time commitment. This also allows firms to expand their services rapidly as they respond to new market demands. Additionally, the firm’s workforce can scale up or down as needed, keeping operational costs lean and profit margins robust.

2. Community and crowd: Harnessing collective knowledge and resources. An ExO thrives on the knowledge, resources and insights of a wider community. By cultivating a network of trusted advisors, clients and partners, CPA firms can build an active community around their services. For example, firms can create virtual communities where clients and advisors engage in real time to share insights, pose questions, and resolve issues. This community-oriented approach strengthens client relationships and provides valuable feedback, driving continuous improvement in service delivery.

Beyond clients, firms can harness the expertise of crowds to improve services and internal processes — processes that allow employees and stakeholders to suggest and vote on innovations, leading to crowdsourced solutions that benefit the entire firm.

3. Algorithms: Driving efficiency and consistency. Incorporating algorithms is a powerful way for CPA firms to automate repetitive tasks, streamline workflows, and reduce human error. For instance, automated data extraction can simplify tax preparation by gathering financial data directly from clients’ systems, reducing the time spent on data entry and review.

Algorithms can also aid in predictive analytics for cash flow management, resource allocation, and client advisory services. By leveraging these technologies, CPA firms not only improve efficiency and accuracy, but can also shift focus to higher-value tasks such as advisory services, thereby increasing client value and profitability.

4. Leveraging assets: Shifting from ownership to access. ExO firms often move away from owning physical assets, instead opting for a shared or leased approach to minimize overhead. For CPA firms, leveraging digital tools and cloud-based platforms provides the same level of functionality without the burden of infrastructure costs.

By utilizing software-as-a-service solutions, CPA firms can avoid the hefty upfront costs of software and hardware, instead paying a manageable subscription fee for flexible access. This keeps operational costs low while ensuring the firm has access to the latest technology, all without the hassle of maintenance and upgrades.

5. Engagement: Cultivating a connected workforce and client base. Employee and client engagement play a central role in the ExO success. Digital platforms like Asana and Microsoft Teams allow for seamless internal communication, fostering collaboration and quick information sharing.

Firms can take engagement a step further by gamifying certain tasks and projects, and rewarding employees for milestones achieved. For clients, engagement can mean creating user-friendly client portals where they can track their progress, upload documents, and receive real-time updates.

Engagement isn’t only about improving experiences; it’s about creating a culture of transparency and trust. When employees and clients feel connected and informed, they are more likely to remain loyal and invested in the firm’s success.

6. Interfaces: Streamlining client and employee interaction. A smooth interface is crucial for managing the complexities of client-firm interactions. Custom portals, for example, can allow clients to access their data, track project statuses, and communicate with advisors in real time.

For CPA firms, the interface attribute focuses on making it easy for clients and employees to navigate systems and processes. A well-designed interface for employees can improve efficiency by making tools and information readily accessible, while clients enjoy a hassle-free experience that adds value to the firm-client relationship.

7. Dashboards: Real-time metrics for data-driven decisions. ExO firms rely on dashboards to monitor their progress toward key performance indicators and goals. Dashboards allow CPA firms to visualize their data in real time, helping partners and managers track client projects, financial metrics, and employee performance.

For example, a dashboard displaying revenue per full-time equivalent provides valuable insights into profitability and efficiency. By monitoring these KPIs, CPA firms can make informed, agile decisions, identifying areas for improvement and optimizing resource allocation.

8. Experimentation: Fostering a culture of innovation. The willingness to experiment is essential for innovation. CPA firms can foster a culture of experimentation by encouraging employees to test new ideas without fear of failure. This could mean piloting a new client service model, testing emerging software, or exploring AI-driven tools for client engagement.

The goal is to embrace agile principles — adapt, test, learn and improve. Small, iterative experiments allow firms to discover what works before investing heavily, reducing risk while positioning the firm as a leader in modern, innovative services.

9. Autonomy: Empowering teams to act. In a traditional CPA firm, hierarchical structures can limit innovation. ExO firms, by contrast, embrace decentralized decision-making, allowing teams to act autonomously in their respective domains. This empowers team members to address client needs proactively, make faster decisions, and deliver services that are both timely and relevant.

Empowered employees are more likely to feel satisfied and engaged, reducing turnover and attracting top talent. Moreover, autonomy helps foster a client-centered approach that enhances service quality and customer satisfaction.

10. Social: Improve teamwork, collaboration and communications. Social technologies in business incorporate the many communication tools that make conversations in the workplace smoother, quicker and way more effective. They encompass communication tools (such as social messaging and discussion forums), collaboration tools (such as cloud-based document management for sharing and real-time editing), and workflow tools (to manage tasks and activity streams.)

Implementing the ExO framework

Transitioning to an ExO model is a journey that often takes 18 to 36 months, depending on the firm’s size, existing infrastructure, and willingness to change. CPA firms can start small, experimenting with one or two attributes before gradually integrating more. Success depends on strong leadership, a shared vision, and an actionable game plan.

The ExO model isn’t just about growth for growth’s sake. It’s about building a firm that can thrive in a rapidly changing environment, delivering exceptional value to clients and creating a work environment where talent can flourish. CPA firms that embrace ExO attributes position themselves as agile, innovative and resilient, equipped to drive profit growth while remaining attractive to both clients and employees.

In conclusion, ExO attributes offer CPA firms a roadmap for transformation.

By adopting an MTP, leveraging assets smartly, embracing staff on demand, and fostering an environment of experimentation and autonomy, CPA firms can enhance profitability, attract top talent, and create enduring client relationships. In a world where change is constant, the ExO model provides a blueprint for sustainable success and a competitive edge in the evolving professional services landscape.

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Accounting

Accountants tackle tariff increases after ‘Liberation Day’

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President Trump’s imposition of steep tariffs on countries around the world is likely to drive demand for accounting experts and consultants to help companies adjust and forecast the ever-changing percentages and terms.

On April 2, which Trump dubbed “Liberation Day,” he announced a raft of reciprocal tariffs of varying percentages on trading partners across the globe and signed an executive order to put the import taxes into effect. Finance executives have been gaming out how to respond to the potential tariffs that Trump has been threatening to impose since before he was re-elected, far exceeding those he actually levied during his first term.

“A lot of CFOs are thinking they are going to pass along the tariffs to their customer base, and about another half are thinking we’re going to absorb it and be more creative in other ways we can save money inside our company,” said Tom Hood, executive vice president for business engagement and growth at the AICPA & CIMA. 

The AICPA & CIMA’s most recent quarterly economic outlook survey in early March polled a group of business executives who are also CPAs and found that 85% said tariffs were creating uncertainty in their business plans, while 14% of the business execs saw potential positive impacts for their business from the prospect of tariffs as increased cost of competing products would benefit them, and 59% saw potential negative impacts to their businesses from the prospect of tariffs. This in turn has led to a dimming outlook on the economy among the executives polled.

“CFOs in our community are telling us that, effectively, they’re looking at this a lot like what happened over COVID with a big disruption out of nowhere,” said Hood. “This one, they could see it coming. But the point is they had to immediately pivot into forecasting and projection with basically forward-looking financial analysis to help their companies, CEOs, etc., plan for what could be coming next. This is true for firms who are advising clients. They might be hired to do the planning in an outsourced way, if the company doesn’t have the finance talent inside to do that.”

The tariffs are not set in stone, and other countries are likely to continue to negotiate them with the U.S., as Canada and Mexico have been doing in recent months.

“The one thing that I think we can all count on is a certain amount of uncertainty in this process, at least for the next several months,” said Charles Clevenger, a principal at UHY Consulting who specializes in supply chain and procurement strategy. “It’s hard to tell if it’s going to go beyond that or not, but it certainly feels that way.”

Accountants will need to make sure their companies and clients stay compliant with whatever conditions are imposed by the U.S. and its trading partners. “This is a more complex tariff environment than most companies have experienced in the past, or that seems to be where we’re headed, and so ensuring compliance is really important,” said Clevenger.

Big Four firms are advising caution among their clients.

“Our point of view is we’re advising all of our clients to do a few things right out of the gate,” said Martin Fiore, EY Americas deputy vice chair of tax, during a webinar Thursday. “Model and analyze the trade flows. Look at your supply chain structures. Understand those and execute scenario planning on supply chain structures that could evolve in new environments. That is really important: the ability for companies to address the questions they’re getting from their C-suite, from their stakeholders, is critical. Every company is in a different spot according to the discussions we’ve had. We just are really emphasizing, with all the uncertainty, know your structure, know your position, have modeling put in place, so as we go through the next rounds of discussions over many months, you have an understanding of your structure.”

Scenario planning will be especially important amid all the unpredictability for companies large and small. “They’re going to be looking at all the different countries they might have supply chains in,” said Hood. “And then even the smaller midsized companies that might not be big, giant global companies, they might be supplying things to a big global company, and if they’re in part of that supply chain, they’ll be impacted through this whole cycle as well.”

Accountants will have to factor the extra tariffs and import taxes into their costs and help their clients decide whether to pass on the costs to customers, while also keeping an eye out for pricing among their competitors and suppliers.

“It’s just like accounting for any goods that you’re purchasing,” said Hood. “They often have tariffs and taxes built into them at different levels. I think the difference is these could be bigger and they could be more uncertain, because we’re not even sure they’re going to stick until you see the response by the other countries and the way this is absorbed through the market. I think we’re going through this period of deeper uncertainty. Even though they’re announced, we know that the administration has a tendency to negotiate, so I’m sure we’re going to see this thing evolve, probably in the next 30 days or whatever. The other thing our CFOs are reminding us of is that the stock market is not the economy.”

Amid the market fluctuations, companies and their accountants will need to watch closely as the rules and tariff rates fluctuate and ensure they are complying with the trading rules. “Do we have country of origin specified properly?” said Clevenger. “Are we completing the right paperwork? When there are questions, are we being responsive? Are we close to our broker? Are we monitoring our customs entries and all the basic things that we need to do? That’s more important now than it has been in the past because of this increase in complexity.”

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Accounting

How to use opportunity zone tax credits in the ‘Heartland’

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A tax credit for investments in low-income areas could spur long-term job creation in overlooked parts of the country — with the right changes to its rules, according to a new book.

The capital gains deferral and exclusions available through the “opportunity zones” credit represent one of the few areas of the Tax Cuts and Jobs Act of 2017 that drew support from both Republicans and Democrats. The impact of the credit, though, has proven murky in terms of boosting jobs and economic growth in the roughly 7,800 Census tracts qualifying based on their rates of poverty or median family incomes. 

Altering the criteria to focus the investments on “less traditional real estate and more innovation infrastructure” and ensuring they reach more places outside of New York and California could “refine the where and the what” of the credit, said Nicholas Lalla, the author of “Reinventing the Heartland: How One City’s Inclusive Approach to Innovation and Growth Can Revive the American Dream” (Harper Horizon). A senior fellow at an economic think tank called Heartland Forward and the founder of Tulsa Innovation Labs, Lalla launched the book last month. For financial advisors and their clients, the key takeaway from the book stems from “taking a civic minded view of investment” in untapped markets across the country, he said in an interview.

“I don’t want to sound naive. I know that investors leveraging opportunity zones want to make money and reduce their tax liability, but I would encourage them to do a few additional things,” Lalla said. “There are communities that need investment, that need regional and national partners to support them, and their participation can pay dividends.”

READ MORE: Unlock opportunities for tax incentives in opportunity zones

A call to action

In the book, Lalla writes about how the Innovation Labs received $200 million in fundraising through public and private investments for projects like a startup unmanned aerial vehicle testing site in the Osage Nation called the Skyway36 Droneport and Technology Innovation Center. Such collaborations carry special relevance in an area like Tulsa, Oklahoma, which has a history marked by the wealth ramifications of the Tulsa Race Massacre of 1921 and the government’s forced relocation of Native American tribes in the Trail of Tears, Lalla notes.

“This book is a call to action for the United States to address one of society’s defining challenges: expanding opportunity by harnessing the tech industry and ensuring gains spread across demographics and geographies,” he writes. “The middle matters, the center must hold, and Heartland cities need to reinvent themselves to thrive in the innovation age. That enormous project starts at the local level, through place-based economic development, which can make an impact far faster than changing the patterns of financial markets or corporate behavior. And inclusive growth in tech must start with the reinvention of Heartland cities. That requires cities — civic ecosystems, not merely municipal governments — to undertake two changes in parallel. The first is transitioning their legacy economies to tech-based ones, and the second is shifting from a growth mindset to an inclusive-growth mindset. To accomplish both admittedly ambitious endeavors, cities must challenge local economic development orthodoxy and readjust their entire civic ecosystems for this generational project.”

READ MORE: Relief granted to opportunity zone investors

Researching the shortcomings

And that’s where an “opportunity zones 2.0” program could play an important role in supporting local tech startups, turning midsized cities into innovation engines and collaborating with philanthropic organizations or the federal, state and local governments, according to Lalla. 

In the first three years of the credit alone, investors poured $48 billion in assets into the “qualified opportunity funds” that get the deferral and exclusions for certain capital gains, according to a 2023 study by the Treasury Department. However, those assets flowed disproportionately to large metropolitan areas: Almost 86% of the designated Census tracts were in cities, and 95% of the ones receiving investments were in a sizable metropolis. 

Other research suggested that opportunity-zone investments in metropolitan areas generated a 3% to 4.5% jump in employment, compared to a flat rate in rural places, according to an analysis by the nonpartisan, nonprofit Tax Foundation.

“It creates a strong incentive for taxpayers to make investments that will appreciate greatly in market value,” Tax Foundation President Emeritus Scott Hodge wrote in the analysis, “Opportunity Zones ‘Make a Good Return Greater,’ but Not for Poor Residents” shortly after the Treasury study. 

“This may be the fatal flaw in opportunity zones,” he wrote. “It explains why most of the investments have been in real estate — which tends to appreciate faster than other investments — and in Census tracts that were already improving before being designated as opportunity zones.”

So far, three other research studies have concluded that the investments made little to no impact on commercial development, no clear marks on housing prices, employment and business formation and a notable boost in multifamily and other residential property, according to a presentation last September at a Brookings Institution event by Naomi Feldman, an associate professor of economics at the Hebrew University of Jerusalem who has studied opportunity zones. 

The credit “deviates a lot from previous policies” that were much more prescriptive, Feldman said.

“It didn’t want the government to have a lot of oversay over what was going on, where the investment was going, the type of investments and things like that,” she said. “It offered uncapped tax incentives for private individual investors to invest unrealized capital gains. So this was the big innovation of OZs. It was taking the stock of unrealized capital gains that wealthy individuals, or even less wealthy individuals, had sitting, and they could roll it over into these funds that could then be invested in these opportunity zones. And there were a lot of tax breaks that came with that.”

READ MORE: 3 oil and gas investments that bring big tax savings

A ‘place-based’ strategy

The shifts that Lalla is calling for in the policy “could either be narrowing criteria for what qualifies as an opportunity zone or creating force multipliers that further incentivize investments in more places,” he said. In other words, investors may consider ideas for, say, semiconductor plants, workforce training facilities or data centers across the Midwest and in rural areas throughout the country rather than trying to build more luxury residential properties in New York and Los Angeles.

While President Donald Trump has certainly favored that type of economic development over his career in real estate, entertainment and politics, those properties could tap into other tax incentives. And a refreshed approach to opportunity zones could speak to the “real innovation and talent potential in midsized cities throughout the Heartland,” enabling a policy that experts like Lalla describe as “place-based,” he said. With any policies that mention the words “diversity, equity and inclusion” in the slightest under threat during the second Trump administration, that location-based lens to inclusion remains an area of bipartisan agreement, according to Lalla.

“We can’t have cities across the country isolated from tech and innovation,” he said. “When you take a geographic lens to economic inclusion, to economic mobility, to economic prosperity, you are including communities like Tulsa, Oklahoma. You’re including communities throughout Appalachia, throughout the Midwest that have been isolated over the past 20 years.”

READ MORE: Can ESG come back from the dead?

Hope for the future?

In the book, Lalla compares the similar goals of opportunity zones to those of earlier policies under President Joe Biden’s administration like the Inflation Reduction Act, the CHIPS and Science Act, the American Rescue Plan and the Infrastructure Investment and Jobs Act.

“Together, these bills provided hundreds of millions of dollars in grant money for a more diverse group of cities and regions to invest in innovation infrastructure and ecosystems,” Lalla writes. “Although it will take years for these investments to bear fruit, they mark an encouraging change in federal economic development policy. I am cautiously optimistic that the incoming Trump administration will continue this trend, which has disproportionately helped the Heartland. For example, Trump’s opportunity zone program in his first term, which offered tax incentives to invest in distressed parts of the country, should be adapted and scaled to support innovation ecosystems in the Heartland. For the first time in generations, the government is taking a place-based approach to economic development, intentionally seeking to fund projects in communities historically disconnected from the nation’s innovation system and in essential industries. They’re doing so through a decidedly regional approach.”

Advisors and clients thinking together about aligning investment portfolios to their principles and local economies can get involved with those efforts — regardless of their political views, Lalla said.

“This really is a bipartisan issue. Opportunity zones won wide bipartisan approval,” he said. “Heartland cities can flourish and can do so in a complicated political environment.”

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Accounting

Ramp releases tool to detect fraudulent AI-generated receipts

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Ramp, a spend management solutions provider, released a new solution within 24 hours in direct response to recent advances in AI image generation that make it easy to create extremely convincing fake receipts that could be used for financial fraud. 

Dave Wieseneck, an “expert in residence” at Ramp who administers the company’s own instance of Ramp, noted that faking receipts is not a new practice. What’s changed is that, with the recent image generation update from OpenAI, it has now become much easier, making what may have once been a painstaking effort into a casual thing done in minutes.

“So while it’s always been possible to create fake receipts, AI has made it super duper easy, especially OpenAI with their latest model. So I think it’s just super easy now and anybody can do it, as opposed to experts that are in the know,” he said in an interview. 

Generated by ChatGPT

AI generated receipt

Rather than try to assess the image itself, the software looks at the file’s metadata for markers particular to generative AI systems. Once those markers are present, the software flags the receipt as a probable fake. 

“When we see that these markers are present, we have really high confidence of high accuracy to identify them as potentially AI generated receipts,” said Wieseneck. “I was the first person to test it out as the person that owns our internal instance of Ramp and dog foods the heck out of our product.” 

While the speed at which they produced this solution may be remarkable, he said it is part of the company culture. The team, especially small pods within it, will observe a problem and stop what they’re doing to focus on a specific need. They get a group together on a Slack channel, work through the problem, code it late at night and push it out in the morning. 

Wieseneck conceded it is not a total solution but rather a first line of defense to deter the casual fraudster. He compared it to locking your door before going out. If the front door is unlocked, a person can just stroll in and steal everything, but will likely give up if it is locked. A professional criminal with tons of breaking and entering experience, however, is unlikely to be deterred by a lock alone, versus a lock plus an alarm system plus an actual security guard. 

“But that doesn’t mean that you don’t lock your door and you don’t add pieces of defense to make it harder for people to either rob your house or, in this case, defraud your company,” he said.

This isn’t to say there’s no plans to bolster this solution further. After all, the feature is only days old. He said the company is already looking into things like pixel analysis and textual analysis of the document itself to further enhance its AI detection capabilities, though he stressed that they want to be very confident it works before pushing it out to customers. 

“We’re focused on giving finance teams confidence that legitimate receipts won’t be falsely flagged. So we want to tread carefully. We have lots of ideas. We’re going to work through them and kind of solve them in the same process we’ve always done here at Ramp,” he said. 

This is likely only the beginning of AI image generators being used to fake documentation. For instance, it has recently been found that bots are also very good at forging passports.

AI fraud ascendant

This speaks to an overall trend of AI being used in financial crimes which was highlighted in a recent report from financial and risk advisory solutions provider Kroll, which surveyed about 600 CEOs, chief compliance officers, general counsel, chief risk officers and other financial crime compliance professionals. What they found was that experts in this area are growing alarmed at the rising use of AI by cybercriminals and other bad actors, and few are confident their own programs are ready to meet this challenge. 

The poll found that 61% of respondents say use of AI by cybercriminals is a leading catalyst for risk exposure, such as through the generation of deep fakes and, likely, AI-generated financial documents. While 57% think AI will help against financial crime, 49% think it will hinder (Kroll said they are likely both right). 

“The rapid-fire adoption of AI tools can be a blessing and a curse when it comes to financial crime, providing new and more efficient ways to combat it while also creating new techniques to exploit the broadening attack surface — be it via AI-powered phishing attacks, deepfakes, or real-time mimicry of expected security configurations,” said the report. 

Yet, many professionals do not feel their current programs are up to the task. The rise in AI-guided fraud is part of an overall projected 71% increase in financial crime risks in 2025. Meanwhile, only 23% rate their compliance programs as “very effective” with lack of technology and investment named as prime reasons. Many also lack confidence in the governance infrastructure overseeing financial crime, with just 29% describing it as “robust.” 

They’re also not entirely convinced that more AI is the solution. The poll found that confidence in AI technology has dropped dramatically over the past two years: those who say AI tools have had a positive impact on financial crime compliance have gone from 39% in 2023 to only 20% today. Despite this, there remains heavy investment in AI. The poll found 25% already say AI is an established part of their financial crime compliance program, and 30% say they are in the early stages of adoption. Meanwhile, in the year ahead, 49% expect their organization will invest in AI solutions to tackle financial crime, and 47% say the same about their cybersecurity budgets. 

To help combat AI-enabled financial crime, Kroll recommended companies form cross-functional teams that go beyond IT and cybersecurity and involve those in AML, compliance, legal, product and senior management. Further, Kroll said there has to be focused, hands-on training with new AI tools that are updated and repeated as the organization implements new AI capabilities and the regulatory and risk landscape changes. Finally, to combat AI-related fraud, Kroll recommended companies maintain a “back to the basics” approach. Focus on fundamental human intervention and confirmation procedures — regardless of how convincing or time-sensitive circumstances appear.

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