ICA Referencing Handbook April 2026 2 Contents 1. Referencing and citation 4 1.1 Why cite? 4 1.2 What should you cite? 5 1.3 When should you cite? 6 1.4 How should you cite? 6 1.5 Source types and citation formats 7 1.5.1 Books (single and multiple authors) 7 1.5.2 Chapters in edited books 8 1.5.3 Journal articles 9 1.5.4 Websites 10 1.5.5 Government and regulatory publications 11 1.5.6 TV programmes and documentaries 11 1.5.7 Radio broadcasts 12 1.5.8 Podcasts 12 1.5.9 Reports and white papers 12 1.5.10 Conference papers 13 1.5.11 Internal company documents 14 1.5.12 ICA course materials 14 1.5.13 Secondary citations 15 1.5.14 Social media and professional platforms 15 1.5.15 Legislation and legal materials 16 1.5.16 Artificial intelligence (AI) and chatbot-generated content 16 1.5.17 Digital Object Identifiers (DOIs) and Uniform Resource Locators (URLs) 21 1.5.18 Personal interviews and conversations 24 1.6 Repeated citations 25 1.6.1 Using ‘Ibid.’ (In the same place) 25 1.6.2 Using ‘op. cit.’ (In the work cited) 26 1.6.3 Shortened references (Alternative approach) 26 1.7 Common referencing mistakes to avoid 27 1.8 Appendices 27 1.9 Tools and resources 27 1.10 Final checklist for referencing 28 3 Policy Ref ICAHBK03 Approval Date 23/03/2026 Document Classification Public Policy Owner Director of Assessment 4 1. Referencing and citation 1.1 Why cite? A citation is a reference to a source that you have used in your work to show where you have obtained the information that you are presenting. Citation is an important skill that will help you to make sense of, and contribute to, your field of work or discipline. You should cite for the following reasons: It allows the reader to distinguish between your views and those of others in the field In well-cited work, it is much easier for the marker to identify and give credit for your own thinking, as distinct from that already published. It helps the reader to quickly find your sources One of the things a marker will want to know is whether you have read and understood the key ideas and contexts for your Reflective Journal. It lends credibility and authority to your arguments When it comes to presenting your work in the form of a publication or presentation, citation demonstrates that you have done your research and that you know what you are writing/talking about; it signals to your audience that they should listen to you. It gives credit to the sources that you consult It is standard academic and professional practice to acknowledge the work of others where it has assisted you. It avoids accusations of plagiarism A correctly cited reflective journal clearly distinguishes between your own work and that of others so that there should be no doubt as to the origin of your research. Note: Don’t overuse citations or quotations Citations or quotations should be used judiciously and in support of, rather than in place of, your own views and wording. You should avoid quoting large passages of text and whole paragraphs. The overuse of quotations might suggest the inability to convey a true understanding of the topic(s) raised and may leave the impression that you are simply cutting and pasting the words and opinions of other people into your reflective journal rather than expressing your own ideas. Instead of using quotations you can paraphrase (express in your own words). By expressing in your own words, the examiner will be able to acknowledge and determine your true level and depth of understanding. Therefore, material copied verbatim from external sources may impact your grade even if correctly referenced. 5 1.2 What should you cite? What you cite is just as important as how and when to cite. You should make a judgement on the reputability and quality of the sources that you consult before deciding to use them in your research. Sources that are regularly used and cited include: • Scholarly or peer-reviewed books and articles • Websites (from reputable organisations) • Media (including documentaries and podcasts) • Textbooks or reference materials • Internal documents from your place of work • ICA course manual(s) • Academic journals • Government publications and regulatory guidance • Industry reports and white papers • Conference proceedings Sources that are not acceptable Not all research methods produce citable sources for the purposes of your assessment. The following are not acceptable sources and must not be cited: • Personal interviews, whether conducted formally or informally, in person, by telephone, by email, or via any other medium • Conversations with colleagues, managers, clients, or industry contacts • Internal meetings, briefings, or training sessions that are not documented in a retrievable internal document Your assessment must be grounded in published, verifiable sources. If a colleague or contact has pointed you toward a useful publication, cite the publication itself, not the conversation. 6 Be careful to use reputable sources, from known organisations or publications. Also be aware that some newspapers, websites, and publications present opinions that may be biased, so consider balancing your sources with others that present an alternative view. You may cite from sources that are in a language other than English, but you must present the information in your assignment in English. 1.3 When should you cite? • Whenever you use someone else’s work or ideas • Every source that you consult, paraphrase, quote, summarise or otherwise refer to or draw upon must be cited • When you wish to cite from a source, such as a book or a website, you will have to consider how to include the source material within your text. There are three main cases to consider: 1. Direct quotation - where you repeat material from your source word for word 2. Indirect quotation - where you refer to a concept or paraphrase an idea 3. Secondary citation - where you quote or refer to material from one source that is reproduced in another. 1.4 How should you cite? In a footnote referencing system, you indicate a reference by • Putting a small number above the line of type directly following the source material (this number is called a note identifier and sits slightly above the line of text) • Putting the same number, followed by a citation of your source, at the bottom of the page • Footnoting should be numerical and chronological: the first reference is 1, the second is 2, and so on • Note identifiers should come at the end of a sentence after punctuation • Footnotes should appear on the same page as the content they are referencing General formatting rules for footnotes: • Use superscript numbers in the text (e.g., ¹) • Number consecutively throughout each evaluation • Place footnote text at the bottom of the page 7 • Single space within each footnote • Leave a blank line between footnotes • Use a smaller font size than body text (typically 10pt if body is 12pt). 1.5 Source types and citation formats The following sections provide guidance on how to cite the most common source types you are likely to encounter in your research. Each section includes an in-text example, the corresponding footnote, the general format, and additional examples covering variations you may come across. Where a source type is not covered here, apply the general principles set out in section 1.4 and use the closest matching format, adapting it as necessary. If you are unsure, contact the ICA Assessment Team. 1.5.1 Books (single and multiple authors) Example (in text): The risk-based approach to anti-money laundering has become the dominant regulatory paradigm across both domestic and international frameworks.¹ Footnote: 1. Paul Allan Schott, Reference Guide to Anti-Money Laundering and Combating the Financing of Terrorism, 2nd ed. (Washington DC: World Bank, 2006), p.45. General format: Author Surname, First name, Title of Book, edition (if not first) (Place of Publication: Publisher, Year), page number(s). Key formatting rules for books: • Italicise the book title • Include edition information only where it is not the first edition (e.g. 2nd ed., revised ed.) • Where there is no identifiable place of publication, use n.p. (no place) • Where there is no identifiable publisher, use n.pub. • Where there is no date of publication, use n.d. Additional examples: Single author: 1. Sarah Brown, Financial Crime Compliance: A Practical Guide (London: Bloomsbury Professional, 2024), p.112. 8 Two authors: 2. Michael Davies and Claire Foster, Risk-Based Approaches to AML Compliance (Oxford: Oxford University Press, 2023), pp.34–38. Three authors: 3. James Elliot, Anna Peterson and Robert Singh, The Compliance Professional’s Handbook (London: LexisNexis, 2024), p.67. Four or more authors: 4. Victoria Chen et al., International Financial Crime: Law, Regulation and Practice (Cambridge: Cambridge University Press, 2023), pp.89–95. No author: 5. Financial Crime Risk Management: An Industry Guide (London: Chartered Institute of Securities and Investment, 2024), p.22. Second or later edition: 6. Richard Alexander, Insider Dealing and Money Laundering in the EU: Law and Regulation, 3rd ed. (Abingdon: Routledge, 2024), p.156. E-book (platform accessed): 7. Louise Delap, Compliance in Financial Services (London: Sweet & Maxwell, 2024), p.88, accessed via ProQuest Ebook Central, 14 January 2025. E-book (Kindle or similar, no fixed page numbers): 8. Thomas Grant, The Future of RegTech (London: Kogan Page, 2024), chap. 3, Kindle edition. 1.5.2 Chapters in edited books Use this format when citing a specific chapter or contribution written by one author that appears within a book edited by a different person or persons. The chapter author and title are given first, followed by the details of the edited volume. Example (in text): The evolution of the suspicious activity reporting regime reflects broader tensions between the operational demands placed on regulated firms and the intelligence needs of law enforcement agencies.² Footnote: 2. Nicholas Ryder, ‘The Proceeds of Crime Act 2002 and the Recovery of Criminal Property,’ in Milestones in Financial Crime Regulation, ed. Barry Rider (London: Institute of Advanced Legal Studies, 2023), pp.112–128. General format: Author Surname, First name, ‘Chapter Title,’ in Book Title, ed./eds. Editor Name(s) (Place of Publication: Publisher, Year), page number(s). Key formatting rules for edited chapters: • The chapter title appears in single quotation marks and is not italicised • The book title is italicised • Use ed. for a single editor and eds. for two or more editors • Always give the page range of the chapter, not just the specific page(s) you have drawn upon, unless citing a single page • Where the edited volume has both a series editor and a volume editor, cite the volume editor 9 Additional examples: Single editor: 9. Emma Reynolds, ‘Customer Due Diligence in Practice,’ in Financial Crime Compliance: Current Issues, ed. David Park (London: Routledge, 2024), pp.45–62. Multiple editors: 10. Rachel Turner, ‘Beneficial Ownership Transparency,’ in Global AML Frameworks, eds. James Robertson and Sophie Williams (Oxford: Hart Publishing, 2024), pp.78–94. Chapter with translated title (non-English source): 11. Hans-Werner Fischer, ‘Geldwäschebekämpfung im europäischen Kontext’ [Combating Money Laundering in the European Context], in Europäisches Finanzrecht, ed. Klaus Müller (Frankfurt: Peter Lang, 2023), pp.201–218. Online edited collection accessed via database: 12. Amanda Foster, ‘The Three Lines of Defence Model,’ in Risk Management in Financial Services, eds. Oliver Bennett and Lisa Anderson (London: Palgrave Macmillan, 2024), pp.33–51, accessed via SpringerLink, 10 January 2025, https://doi.org/10.1007/978-3-030-12345-6_3. 1.5.3 Journal articles Example (in text): Smith and colleagues demonstrate that regulatory technology implementation correlates with improved compliance outcomes across multiple jurisdictions.³ Footnote: 3. Alexander Smith, Rachel Turner and David Park, ‘RegTech and Compliance Effectiveness: A Multi-Jurisdictional Study,’ Journal of Financial Crime 29, no. 4 (2024): pp.456-478. General format for journal articles: Author(s), ‘Article Title,’ Journal Name Volume number, Issue number (Year): page range. Additional examples: Single author article: 8. Victoria Chen, ‘Artificial Intelligence in Transaction Monitoring,’ Compliance and Regulation Review 15, no. 2 (2025): pp.89-112. Article with DOI: 9. James Robertson et al., ‘Evolving Approaches to Financial Crime Detection,’ International Review of Law and Economics 71 (2024): pp.234-256, https://doi. org/10.1016/j.irle.2024.106234 Online journal: 10. Emma Williams, ‘Cryptocurrency Regulation: Emerging Frameworks,’ Digital Finance Journal 8, no. 1 (2024), accessed 15 January 2025, https://www. digitalfinancejournal.com/articles/crypto-regulation-2024 10 1.5.4 Websites Example (in text): The FCA’s recent guidance emphasises the importance of a risk-based approach to consumer duty implementation.⁴ Footnote: 4. Financial Conduct Authority, ‘Consumer Duty: Implementation Guidance for Firms,’ FCA website, 15 October 2024, accessed 10 January 2025, https://www.fca.org.uk/ publications/finalised-guidance/consumer-duty-implementation General format for websites: Author/Organisation, ‘Article/Page Title,’ Website Name, date published, accessed date, full URL. Important notes for web sources: • Always include the full URL • Include both publication date (if available) and access date • For sources without a clear author, use the organisation name • For sources without a date, use ‘n.d.’ (no date) Additional examples: News article: 11. Oliver Bennett, ‘New AML Regulations Come into Force,’ Financial Times, 3 December 2024, accessed 8 January 2025, https://www.ft.com/content/aml-regulations-2024 Organisation webpage (no individual author): 12. Bank of England, ‘Regulatory Expectations for Financial Crime Systems and Controls,’ Bank of England website, 22 November 2024, accessed 12 January 2025, https://www. bankofengland.co.uk/prudential-regulation/publication/2024/financial-crime-guidance Blog post: 13. Rachel Morrison, ‘The Future of Compliance Technology,’ Compliance Week Blog, 5 September 2024, accessed 9 January 2025, https://www.complianceweek.com/blog/future- compliance-technology No author, no date: 14. International Compliance Association, ‘Professional Standards for Compliance Practitioners,’ ICA website, n.d., accessed 11 January 2025, https://www.int-comp.org/ professional-standards 11 1.5.5 Government and regulatory publications Example (in text): The latest supervisory expectations emphasise the need for robust governance frameworks in managing financial crime risk.⁵ Footnote: 5. Financial Conduct Authority, Financial Crime Thematic Review: Systems and Controls (London: FCA, 2024), p.18. General format: Organisation, Title (Place: Publisher/Organisation, Year), page number(s). Additional examples: UK government publication: 15. HM Treasury, National Risk Assessment of Money Laundering and Terrorist Financing 2024 (London: HM Treasury, 2024), pp.45-52. Regulatory guidance: 16. Prudential Regulation Authority, Operational Resilience: Impact Tolerances for Important Business Services (London: PRA, 2024), p.12. International organisation: 17. Financial Action Task Force, Guidance on Digital Identity (Paris: FATF, 2024), pp.8-15. Command paper: 18. HM Government, Economic Crime Plan 2023-2026 (London: The Stationery Office, 2023), Cm 123, p.34. Online government guidance: 19. National Crime Agency, ‘Suspicious Activity Reports Annual Report 2024,’ NCA website, June 2024, accessed 14 January 2025, https://www. nationalcrimeagency.gov.uk/sar-annual-report-2024 1.5.6 TV programmes and documentaries Example (in text): The documentary explored the intersection of technology and financial crime, demonstrating how criminals exploit digital payment systems.⁶ Footnote: 6. Panorama: The Cryptocurrency Con, BBC One Television, 15 January 2025. General format: Programme Title, Channel, date broadcast. Additional examples: With presenter/reporter: 20. Presented by Fiona Bruce, Crimewatch: Financial Fraud Special, BBC One Television, 8 November 2024. Documentary with director: 21. Directed by Sarah Chen, The Great Crypto Heist, Netflix, 22 September 2024. Interview segment: 22. Rachel Reeves, interview by Laura Kuenssberg, Sunday with Laura Kuenssberg, BBC One Television, 12 January 2025. 12 1.5.7 Radio broadcasts Example (in text): The discussion highlighted the challenges facing UK financial regulators in adapting to digital assets.⁷ Footnote: 7. Today Programme, BBC Radio 4, 17 January 2025. General format: Programme Title, Station, date broadcast. Additional examples: With specific segment/interview: 23. Nikhil Rathi, interview by Nick Robinson, Today Programme, BBC Radio 4, 9 December 2024. Financial/business programme: 24. Money Box, BBC Radio 4, 6 January 2025. 1.5.8 Podcasts Example (in text): The discussion highlighted emerging trends in RegTech implementation across European financial institutions.⁸ Footnote: 8. Sarah Thompson and David Martinez, ‘The RegTech Revolution,’ Compliance Matters, podcast audio, 15 December 2024, accessed 10 January 2025, https://www. compliancematters.com/episodes/regtech-revolution General format: Host/Speaker(s), ‘Episode Title,’ Podcast Name, podcast audio, date published, accessed date, URL. Additional examples: Single host: 25. Michael Chen, ‘AI in Financial Crime Detection,’ The Compliance Podcast, podcast audio, 3 January 2025, accessed 15 January 2025, https://www.compliancepodcast. com/ep-142 Interview format: 26. Emma Roberts, interview with Lisa Anderson, ‘Consumer Duty Implementation,’ FCA Connect, podcast audio, 18 November 2024, accessed 8 January 2025, https://www.fcaconnect.com/consumer-duty-2024 Episode from series: 27. ‘Crypto Regulation in 2025,’ Financial Crime Review, podcast audio, Series 3, Episode 12, 2 January 2025, accessed 14 January 2025, https://www. fcreview.com/s3e12 1.5.9 Reports and white papers Example (in text): The report identified significant gaps in current anti-money laundering frameworks, particularly regarding beneficial ownership transparency.⁹ 13 Footnote: 9. FATF, Targeted Update on Implementation of the FATF Standards on Virtual Assets and Virtual Asset Service Providers (Paris: FATF, 2024), pp.12-18. General format: Organisation, Title (Place: Publisher, Year), page range. Additional examples: Industry report: 28. PwC, Global Economic Crime and Fraud Survey 2024 (London: PwC, 2024), p.34. Think tank report: 29. Royal United Services Institute, The Future of Financial Intelligence (London: RUSI, 2024), pp.8-15. International organisation report: 30. World Bank, Combating Illicit Finance: A Development Priority (Washington DC: World Bank, 2024), pp.45-52. White paper: 31. Deloitte, Artificial Intelligence in Compliance: Opportunities and Challenges (London: Deloitte, 2024), p.23. Report series: 32. Thomson Reuters, Cost of Compliance 2024, Special Report (London: Thomson Reuters, 2024), pp.16-19. 1.5.10 Conference papers Example (in text): Recent research suggests a paradigm shift in compliance monitoring approaches, with greater emphasis on real-time analytics.¹⁰ Footnote: 10. Michael Chen and Sophie Williams, ‘Real-Time Compliance Monitoring: Lessons from Implementation’ (paper presented at the International Compliance Conference, London, 15 October 2024). General format: Author(s), ‘Paper Title’ (paper presented at Conference Name, Location, date). Additional examples: Conference paper - single author: 33. Amanda Foster, ‘Machine Learning Applications in Transaction Monitoring’ (paper presented at the FinTech Compliance Forum, Singapore, 8 March 2024). Published conference proceedings: 34. James Robertson, ‘Blockchain and Regulatory Compliance,’ in Proceedings of the 2024 European Financial Services Conference, ed. Rachel Turner (Brussels: EFSC, 2024), pp.156-168. Panel discussion: 35. Lisa Anderson et al., ‘The Future of AML: A Panel Discussion’ (panel discussion at ICA Annual Conference, Birmingham, 12 June 2024). 14 1.5.11 Internal company documents Example (in text): The organisation’s risk appetite framework establishes clear parameters for acceptable risk exposure across different business lines.¹¹ Footnote: 11. [Organisation Name], Risk Appetite Framework 2024 (Internal document, 2024), p.8. General format: Company/Organisation, Document Title (Internal document, Year), page number(s). Note: Be mindful of confidentiality when citing internal documents. You may need to anonymise company-specific information. Additional examples: Internal policy: 36. [Organisation Name], Anti-Money Laundering Policy (Internal policy document, Version 3.2, 2024), para. 4.5. Internal report: 37. [Organisation Name], 2024 Compliance Risk Assessment Report (Internal report, January 2025), pp.12-15. Anonymised example: 38. Financial Services Organisation, Financial Crime Risk Assessment Methodology (Internal methodology document, 2024), p.6. 1.5.12 ICA course materials Example (in text): The ICA course materials emphasise the importance of understanding both the letter and spirit of compliance regulations.¹² Footnote: 12. International Compliance Association, Professional Diploma in Compliance Course Manual (Birmingham: ICA, 2024), Unit 4, pp.67-72. General format: International Compliance Association, Course Title (Birmingham: ICA, Year), Unit/Section, page number(s). Additional examples: Specific module: 39. International Compliance Association, Professional Postgraduate Diploma in Financial Crime Compliance: Module 3 - Financial Crime Typologies (Birmingham: ICA, 2024), pp.23-28. ICA guidance document: 40. International Compliance Association, Assessment Guidance for Learners (Birmingham: ICA, 2024), p.15. ICA webinar: 41. International Compliance Association, ‘Understanding the Consumer Duty,’ ICA webinar, presented by Emma Wilson, 14 September 2024. 15 1.5.13 Secondary citations Use secondary citations when you need to cite a source that you have not directly accessed, but which is quoted or discussed in another source. You should always try to find and cite the original source where possible. Example (in text): In their 2023 report, the National Crime Agency noted that “cryptocurrency-related money laundering cases have increased by 300% over the previous year”.¹³ Footnote: 13. National Crime Agency, Suspicious Activity Reports Annual Report 2023 (2023), p.45, quoted in Sarah Thompson, Emerging Threats in Financial Crime (London: Routledge, 2024), p.89. General format: Original Author, Original Title (Year), page number, quoted in Secondary Author, Secondary Source Title (Place: Publisher, Year), page number. Additional examples: Academic article quoted in book: 42. James Robertson, ‘Machine Learning in AML Detection,’ Journal of Financial Crime 28, no. 3 (2023): p.234, quoted in Michael Chen, Technology and Financial Crime Prevention (Oxford: Oxford University Press, 2024), p.156. Report quoted in journal: 43. Financial Conduct Authority, Financial Crime Thematic Review (2023), p.12, cited in Emma Williams and David Park, ‘Regulatory Expectations in Financial Crime Prevention,’ Compliance Review Quarterly 12, no. 2 (2024): p.78. 1.5.14 Social media and professional platforms Note: Social media should be used sparingly and only when it represents an official organisational position or expert commentary not available elsewhere. Example (in text): The FCA used its official channels to clarify the timeline for Consumer Duty implementation.¹⁴ Footnote: 14. Financial Conduct Authority (@TheFCA), ‘Consumer Duty implementation timeline confirmed,’ X (formerly Twitter), 5 November 2024, accessed 10 January 2025, https://x.com/TheFCA/status/1234567890 General format: Author/Organisation (Account handle), ‘Post content/summary,’ Platform name, date posted, accessed date, URL. Additional examples: LinkedIn post: 44. Nikhil Rathi (@nikhilrathi), ‘Reflections on regulatory priorities for 2025,’ LinkedIn, 8 January 2025, accessed 15 January 2025, https://www.linkedin.com/posts/ nikhilrathi-2025-priorities 16 YouTube video: 45. International Compliance Association, ‘Understanding Financial Crime Risk Assessment,’ YouTube video, 12:34, 22 November 2024, accessed 9 January 2025, https://www.youtube.com/watch?v=example123 1.5.15 Legislation and legal materials Statutes (Acts of Parliament): Example: 46. Proceeds of Crime Act 2002, c.29. Statutory Instruments: Example: 47. Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692. EU Directives (for historical context): Example: 48. Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing [2015] OJ L141/73 (Fourth Money Laundering Directive). Case law: Example: 49. R v Da Silva [2006] EWCA Crim 1654. Example in footnote with discussion: The Supreme Court confirmed that suspicion requires a reasonable basis in fact.⁵⁰ Footnote: 50. R (on the application of UMBS Online Ltd) v Serious Organised Crime Agency [2007] EWCA Civ 406, at para. 32. 1.5.16 Artificial intelligence (AI) and chatbot-generated content Important context: As outlined in Section 4.7 (Use of Chatbots), AI tools can be used legitimately for research and idea generation, but their use must be properly acknowledged and their output critically evaluated. Any text generated by AI that you include in your work must be cited, and verbatim use of AI-generated content is not acceptable. General principles for citing AI: • Always cite when you use AI-generated content • Include the AI tool name, version (if known), prompt used, date, and company • Treat AI as a source that requires verification 17 • Be aware that AI-generated content cannot be retrieved by readers • Remember that AI can produce inaccurate or biased information Example 1: General AI assistance (in text): Initial research using AI tools suggested several frameworks for understanding regulatory technology implementation, though these required verification through peer-reviewed sources.⁵¹ Footnote: 51. ChatGPT (GPT-4), response to “Explain regulatory technology implementation frameworks,” OpenAI, 15 January 2025. Example 2: Using AI for definitions or explanations: The concept of ‘embedded compliance’ can be understood as the integration of regulatory requirements directly into business processes and systems.⁵² Footnote: 52. Claude (Sonnet 4), response to “Define embedded compliance in financial services context,” Anthropic, 18 January 2025. Example 3: AI-assisted analysis (paraphrased): When exploring the relationship between transaction monitoring thresholds and false positive rates, preliminary analysis suggested an inverse correlation that required further investigation through academic literature.⁵³ Footnote: 53. ChatGPT (GPT-4), response to “Analyze the relationship between AML transaction monitoring thresholds and false positive rates,” OpenAI, 10 January 2025. Analysis subsequently verified through Smith et al. (2024). General format for AI citations: AI Tool Name (Version/Model), response to “prompt text,” Company, date of interaction. Additional examples: Copilot/Bing AI: 54. Microsoft Copilot, response to “Summarise key requirements of the Money Laundering Regulations 2017,” Microsoft, 12 January 2025. Google Bard/Gemini: 55. Google Gemini, response to “Explain the three lines of defence model in compliance,” Google, 14 January 2025. Claude: 56. Claude (Sonnet 3.5), response to “What are the main differences between rule- based and risk-based AML approaches?,” Anthropic, 16 January 2025. Specialised AI tools: 57. Grammarly AI, suggestions for “improving clarity in compliance risk assessment section,” Grammarly, 20 January 2025. Code or data generation: 58. GitHub Copilot, Python code for “transaction pattern analysis,” GitHub/Microsoft, 11 January 2025. 18 Important considerations when using AI-generated content: 1. Verification is essential AI-generated information must be verified against authoritative sources. Never rely solely on AI for factual claims, regulatory requirements, or technical information. Example of proper verification: WRONG: “According to ChatGPT, the Money Laundering Regulations 2017 require...” RIGHT: “The Money Laundering Regulations 2017 require...” [with footnote to the actual legislation] 2. Use AI as a starting point, not an endpoint AI can help you: • Generate initial ideas or frameworks • Understand complex concepts • Identify areas for further research • Draft initial structures AI should not be used to: • Replace your own critical thinking • Generate large portions of your assessment verbatim • Provide definitive answers on regulatory requirements • Substitute for reading primary sources 3. Integration with other sources When AI contributes to your research, acknowledge it but support your arguments with authoritative sources: Example: Initial exploration of compliance technology trends using AI assistance identified several emerging areas for investigation.⁵⁹ Subsequent research confirmed that RegTech adoption has increased significantly across the financial services sector, with particular growth in transaction monitoring and customer due diligence applications.⁶⁰ Footnotes: 59. ChatGPT (GPT-4), response to “What are current trends in compliance technology?,” OpenAI, 8 January 2025. 60. Deloitte, RegTech Universe 2024 (London: Deloitte, 2024), pp.12-18. 19 4. Transparency about AI use Be transparent about how you’ve used AI in your research process: Acceptable approaches: “AI tools were used to generate initial research questions, which were then investigated through academic literature” “ChatGPT was consulted to clarify technical terminology, with definitions verified against regulatory guidance” “AI assistance was used for brainstorming potential case study examples, which were then researched independently” 5. Recording AI interactions Keep records of your AI interactions for your own reference: • Save the full conversation or prompt • Note the date and time • Record the AI version/model used • Keep track of any follow-up prompts • Document how you verified the information 6. Limitations of AI citations Be aware that: • AI responses cannot be retrieved by readers (unlike a published article) • AI responses may vary for the same prompt at different times • AI tools are updated regularly, changing their capabilities and outputs • Academic conventions for AI citation are still evolving When NOT to cite AI: • You do not need to cite AI when: • Using AI for general writing assistance: • Grammar checking • Spell checking • Basic sentence restructuring • Formatting assistance 20 Using AI as a search tool: If you use AI to help you find sources, cite the sources themselves, not the AI Brainstorming that doesn’t appear in your work: If you used AI to generate ideas but completely rewrote everything in your own words based on your own independent research, you do not need to cite the AI. Examples of proper vs. improper AI use: IMPROPER (Plagiarism): Using ChatGPT to write entire sections of your evaluation and including this text without citation or with minimal changes. IMPROPER (Over-reliance): Asking ChatGPT “Write an evaluation of the AML masterclass covering money laundering typologies, risk-based approaches, and suspicious activity reporting” and using the response as your submission. PROPER (Research assistance): Asking ChatGPT “What are the key elements I should consider when analysing AML risk- based approaches?” and using the response to guide your reading of academic literature and regulatory guidance. PROPER (Clarification): Using Claude to help you understand a complex regulatory concept, then reading the actual regulation and explaining it in your own words, citing Claude for the initial explanation. PROPER (Critical engagement): Asking an AI tool for its analysis of a compliance issue, citing this, but then critically evaluating the response using authoritative sources and your professional experience. AI and academic integrity: Remember that your Reflective Journal must demonstrate: • Your own critical thinking • Your own professional experience and application • Your own research and reading • Your own analysis and evaluation