Building a Bank with a Heart: Inside DBS’s Approach to Crypto, Compliance, and AI with Chee Kin Lam

Ari Redbord (00:02):

I am Ari Redbord and this is TRM Talks. I'm Global Head of Policy at TRM Labs, we provide blockchain intelligence software to support law enforcement investigations and to help financial institutions and cryptocurrency businesses mitigate financial crime risk within the emerging digital asset economy. Prior to joining TRM spent 15 years in the US federal government, first as a prosecutor at the Department of Justice, and then as a Treasury Department official where I worked to safeguard the financial system against terrorist financiers, weapons of mass destruction proliferators, drug kingpins, and other rogue actors. On TRM Talks, I sit down with business leaders, policymakers, investigators, and friends from across the crypto ecosystem who are working to build a safer financial system. On today's TRM Talks, I sit down with the head of legal and compliance for DBS Bank, Chee Kin Lam.

(01:02):

But first, Inside the Lab, where I share data-driven insights from our blockchain intelligence team. Over the last few weeks, Mexico has seen intensified federal operations targeting senior figures within the Helesco New Generation Cartel or CJNG. Raids and arrests dominate the headlines. But to understand where this fight is going, we have to look beyond the kinetic and focus on the financial architecture. Cartels like CJNG are vertically integrated transnational enterprises. They manage precursor procurement, oversee fentanyl production, control cross-border logistics, and operate layered laundering systems capable of absorbing billions of dollars annually. Leadership disruption may change tempo. Financial infrastructure determines survival. The synthetic drug economy is fundamentally a financial system. Retail drugs in the United States generate massive volumes of US dollar cash. That cash must be collected, laundered, converted, and transferred upstream to pay precursor suppliers and intermediaries. Increasingly, cryptocurrency is embedded in that settlement cycle. TRM estimates that cartel-associated money launderers have moved more than three billion on chain as of January 2026, most of it in the past two years.

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Digital assets are typically used as a bridge. US drug cash is aggregated, converted into crypto, often USDT on the Tron blockchain via OTC or peer-to-peer channels, and transferred cross-border to Chinese intermediaries. Those intermediaries then purchase goods or pay precursor manufacturers directly. Goods move south, pesos move back to the cartel. The cycle repeats. Cryptocurrency doesn't replace traditional laundering. It compliments it. It offers speed, liquidity, and cross-border settlement, outside correspondent banking rails. But here's the key. Blockchains are transparent. Funds move through identifiable patterns, pass-through wallets, consolidation nodes, exchanges, and liquidity providers. The investigative surface shifts from physical cash seizures to financial intelligence. Cartels thrive on adaptability. Disrupting them requires targeting financial intermediaries and integrating blockchain intelligence into homeland security operations. The deeper contest is not just on the streets. It's in the financial system, and those who can map and disrupt that architecture will shape what comes next in Mexico and beyond.

(03:33):

And now, Chee Kin Lam. Today I am joined by a very special guest, Chi Kin, the head of legal and compliance at DBS. Thank you so much for joining TRM Talks.

Chee Kin Lam (03:48):

Thanks so much, Ari. Thanks for having me.

Ari Redbord (03:49):

You lead legal and compliance really at one of the first global banks to get into the digital asset space. We've seen a year or more now of what I'd call sort of real institutional adoption or a lot more financial institutions thinking about getting in here. Would you talk a little bit about your journey and background and then really how you got to this place at DBS?

Chee Kin Lam (04:10):

Yeah, you can tell already that I love words and concepts. If I was any better with my hands, I'd be a surgeon. I was any better with numbers, I'd be a quant. Yeah, but no, I have to do words and concepts. So basically, I'm a lawyer by training. I've been doing this for 30 plus years. I had JP Morgan on my CV, Standard Chartered on my CV. So done my US tour, done my kind of UK/European tour. This was before Brexit. And so now doing a tour in the Asian community. Because I do both legal and compliance, I like to think we straddle both the complexity of the legal issues, but also the complexity of the regulatory and compliance issues that we have to deal with.

Ari Redbord (04:52):

One interesting thing is I'm not sure I've ever talked to anyone who had spent significant time at arguably one of the most important banks in the UK, certainly one of the most important banks in the US. And now in Singapore, talk me through that journey and maybe some of the differences you experienced there, because that's really an extraordinary piece of that career journey.

Chee Kin Lam (05:11):

I really think this was fantastic. And I would really put it all down to people and culture. So fundamentally, the way of getting things done in a JP Morgan is not the same as the way of getting things done in a Standard Charted, and it's not the same way of getting things done in DBS. So what you've done got to do is to develop all these ways of dealing with people and ideas and getting your way and influencing people that is incredibly diverse. And I think that's fundamentally what I had to learn. In the US, you've got this idea about robust debate and nothing's personal, but you leave everything on the table. In standard charter, there's a lot of influencing. There's a lot of cultural aspects of an English institution that you have to design for. Standard Chartered also had a phenomenal global footprint from Angola to the US to Hong Kong that you had to really learn in terms of dealing with people from those kinds of diverse backgrounds.

(06:16):

And I think when you talk about emerging market with Asian ambition and Asian aspiration, but also tuning away from pure individualism, which is some of the ideas that embody a American cultural backdrop to a lot of the ideas of community and the value of community, that's what you get from an Asian institution. So I think it's things like that that I've learned over the years.

Ari Redbord (06:38):

Really extraordinary. And I feel like it's also been a bit of an innovation journey. Obviously looking at DBS today, one of the first institutions to receive the digital payment token from the Monetary uthority of Singapore. Would you talk to me about maybe those digital roots or at least how you've been thinking about that journey?

Chee Kin Lam (06:55):

I think by design from 2013, 2014, DBS was always all in on digital transformation. The predominant narrative is cloud infrastructure, data, and startup mentality. A lot of the stuff that drove growth in DBS over the last 10-odd years. Airlight to that, we've learned a lot about reflections on trust, safety, and how to really architect a future that is grounded on those ideas. So then when you apply it to initiatives, and you can pretty much apply it to anything, including the blockchain, if we are saying that there is a prospect of a future that is driven by the blockchain, you then have to ask yourselves, well, if we want to get involved, then necessarily that future will involve trust and confidence, which is the bedrock of banking. So that's kind of like the roots of it. Then why blockchain? I think that there are maybe two ways to take a view on the blockchain.

(08:01):

One way to take a view on the blockchain is the financial asset financial markets view of the blockchain, which is broaden and deepen these markets as much as possible so that they become like other asset classes, equities, effects, everything that we've already known. The other way to look at this is the future of financial infrastructure. So in the same way, then you can talk about payment rails coming up. In our job, we also think about things like shadow banking and alternative banking infrastructure, but the blockchain does represent an optionality in relation to the future of financial architecture. So I think these two ideas that you say, okay, it's a broadening asset for us. And secondly, it represents a potential future for financial infrastructure. Then the decision comes down to, well, let's engage. And if we engage, then let's contribute by trying to design for trust, confidence, safety, and so on and so forth.

(08:57):

So that's a pretty long way of answering the question, but I think it's a very reasoned approach that we've been taking as to why we've chosen this route.

Ari Redbord (09:05):

Really extraordinary. And obviously it's very much the way we think about, I think, the growth of the ecosystem at TRM. And that is, hey, this is going to grow. There's an inevitability around this. We've already seen in the last year, two years, institutional adoption and real growth and stablecoin activity. You have to build compliance as critical infrastructure across this new sort of financial system. Do you remember a time in your career where the notion of financial technology or even digital assets really clicked with you where you said, "Hey, this is actually somewhere I want to spend some time."

Chee Kin Lam (09:38):

So one more bit about background, because I'm a markets guy. So fundamentally fundamental at my core, I'm a derivatives lawyer. So in derivatives, we've always had new futures contracts being launched. A long time ago, it's like broiler chickens and orange juice, right? Which are incredibly traded commodities today. There will be oil futures. There was the rise of the credit derivative. So we learn a lot about how to give rise to new financial assets and then how to develop the ecosystems associated with these financial assets. So I think the big time when this started clicking, I remember in the early days we were thinking, it's not a currency, it's not a medium of exchange, it's not legal tender, there's not much, but the market capitalization started growing. So then it hits a trillion, then it hits two trillion. We're dating ourselves today it's two trillion plus.

(10:35):

It used to be four trillion.

Ari Redbord (10:38):

Absolutely.

Chee Kin Lam (10:39):

Capitalization grows, you have to say that the forces of supply and demand as associated with the asset have a degree of momentum around it. And I think the point that you said institutional money starts coming in and you then have these characteristics of the early days of the development and maturity of an asset class that becomes very, very interesting. So I think you then got to make your decision or your, let's also be quite truthful about it, your bets or your capital allocation decisions as to whether we engage or we don't engage. And all of us will make those decisions, yes or no, and we have to live or die buy those types of decisions. I think I made that decision for myself late 2015, 2016, around that time. Before that, I was juries out, not completely sure.

Ari Redbord (11:29):

It's early. I mean, that was still very, very early in this space if you really think about it, especially where you're talking about you've worked for essentially the most conservative institutions in the world. Large financial institutions are not usually leaning right into these types of technological changes. DBS was early, but still 2014, 2015 is really early. Talk me through maybe a little bit more about DBS and the work there.

Chee Kin Lam (11:56):

We're pretty much what you'd expect of a kind of universal bank. I think that's the type of word that most people will use, your usual commercial banking, corporate banking, private banking, retail banking type of unit. We do have an investment banking business. It's largely aligned to our markets business. And so a lot of what we do is fundamentally around serving our clients in the markets in which we have chosen to strategically allocate capital. We do like to say quite a bit about serving clients and making sure we do this the Asian way. And some numbers, I guess we are market cap about 160 something billion market capitalization. So not the biggest in the world, but also not the smallest in the world, pretty decent. But ultimately, I think it is this desire to basically service clients that takes us into areas of due ambition. AI would be one of them, blockchain would be one of them and so on and so forth.

Ari Redbord (12:58):

You were talking about 2014, 2015. Maybe I can back you up there for a minute. How were you thinking about the risks and sort of compliance then maybe, and how has that developed over time as you're thinking about the ecosystem today?

Chee Kin Lam (13:14):

I think at that time, the conversations were really dominated by anti-money laundering, but I really want to emphasize this as well. Every time somebody has to look at these risks, we cannot look at it one dimensionally. The types of issues that we will get into, governance, market abuse, conflicts of interest, the types of issues that we'll have to deal with in relation to the incremental risk represented by a new financial asset will be extremely diverse and multifaceted. However, at that point in time, I think the dominant conversation was anti-money laundering and how kind of illicit or bad actors were using the tokens inappropriately and how to get on top of that. So that is really the type of the issue that we were wrestling with at that time. I'll use some words. I think you find some of these words in the literature as well, coin purity or what I like to call the problem of the poison token.

(14:13):

That means the transaction in feart, which is between point A and point B is tainted not because of the conduct of person A or person B. It's tainted because somebody else who has touched the token has tainted the token itself. And that I think was the incremental risk that we were all grappling with and saying, well, how do we get better and managing that risk? How do we articulate it? How do we put some guardrails around it and so on and so forth that caused us to think very deeply.

Ari Redbord (14:48):

When I'm asked about the thorniest questions when it comes to crypto compliance, that it usually starts with something along those lines. And it's how many hops must we look back. Yeah, that's usually the way it's couched, but I think that really makes sense. And I've actually gone to regulators, frankly, from everyone from the US Treasury Department to MAS and elsewhere. And you hear about a risk-based approach. And I actually agree in terms of, I wouldn't want to say you go four hops back. Maybe that's too far, maybe that's too little, but it really becomes an interesting question. So has your thinking around risk then evolved? I got the sense that it felt more holistic today than it maybe did in those early days.

Chee Kin Lam (15:33):

Yeah, yeah, yeah. Today, I think it's way more mature. I also think we have acknowledged two big things. One is that of course, even the crypto natives have also matured and have learned an incredible amount sometimes better than traditional finance in relation how to manage these risks. I think governance has gotten a lot better. I think I see so many more independent checks and balances in the system. Then secondly, I think the technology, I mean, you guys, but also your competitors, the technology has matured, it's gotten better. And actually I think AI is augmenting the technology to become particularly interesting. So wherever you decide to set your risk appetite, it's in the context of, I think, a growing degree of responsibility in the system, and also a growing degree of technological maturity that enables some of the risk management that we're talking about. So I think that's how my thinking has evolved.

(16:34):

I think the risks are the same, but we've got some better tools and people to manage it better.

Ari Redbord (16:39):

I saw a quote recently that talked about DBS being an AI-enabled bank with a heart. I loved that. How are you thinking about AI?

Chee Kin Lam (16:48):

I think this is my reflection, and I'm going to kind of say this in perhaps a constructively provocative way. Is the rate of change external or internal? That means within organizations and outside organizations is the rate of change that is hitting the human being, exceeding the rate of the human being's ability to adapt to that rate of change, right? And there's some very, very credible arguments. The answer is yes. So from a social perspective, realizing that the human being getting inundated with all this is incredibly challenging. Then makes you ask the question, well, we've had many, many structural productivity shifts over time,

(17:36):

The word processor replacing the typewriter. So then you've got to say that that is a prospect, a real prospect that AI is going to give us that structural productivity. However, presenting this as a tension from a corporate perspective, presenting is a tension between your human workforce and your AI is not necessarily in your best interests. So I think the reason why DBS has gone this way is we've tried to say, look, let's try to reconcile some of the dilemmas facing the human being, which is this point about rate of change with, in a sense, the promise of the technology and bring both viewpoints together so that we can move forward in a kind of like, well, okay, I alluded to this earlier, in less of a polarized fashion, less of a single individual's viewpoint, but in a way, coming up with a narrative that brings both viewpoints together, I think that's how we've chosen to think about it and then to move forward.

Ari Redbord (18:39):

And what does that look like in practice?

Chee Kin Lam (18:40):

So actually when we do an AI project, so we run a ton of stuff within even my function or within the bank as a whole, what we also try to think about is the employee value proposition, which means why should the employee do this? And if we cannot come up with a very, very good narrative, then we've got to make certain concessions that this is largely an efficiency or a cost play without that compelling and employee value proposition. But almost every time I would say I would argue this, almost every time I've had one of these initiatives, so I just throw out one example there. We use LLMs, generative AI ,to write suspicious transaction reports. So we file tens of thousands of these things a year and we have hundreds of employees, all of whom are writing these things inconsistently, all of whom are having to access extremely large databases to distill information which actually the LLM can produce a pretty decent first cutoff.

(19:41):

So without digressing too much more, the employee value proposition is really, really clear. Instead of spending two hours laboring over the data and trying to, the LLM will produce a first cut for you and that would free you up to make your risk judgment decision making better. So that's a very, very simple example of how the employee value proposition coexists with the optimization that the technology represents.

Ari Redbord (20:07):

I agree. And I mean, I hear about this narrative about AI agents replacing human functions. And I know it exists and it will happen, but at TRM, we now use AI at every layer of our platform. We encourage every one of our employees to be using it in really all of their workflows, but it's supercharged, already productive people in many respects. And to your point, it's really sort of like, "Hey, if you can do things faster, you can focus on really the harder problems, spend more time on those harder problems." And I like that, that sort of the AI bank with a heart. I think that's what you're really getting at there, that we're building up our employees and our customers. We're not replacing them in some way. Speaking of AI, one thing we reported on recently is that we saw about a 500% increase over the last year in AI enabled scams and fraud.

(21:00):

I know scams and fraud are a huge focus for you in terms of risk mitigation. It's really become a global epidemic. Talk me through a little bit about how you think of scams and fraud risk today.

Chee Kin Lam (21:11):

So I think first big point is this. The data is showing that the unauthorized scam, that means somebody hacked my bank account, somebody hacked the telecommunication service provider, somebody ... The unauthorized scam is really falling off. So we've spent years fighting these things after about ... This is just about in the middle of COVID. So after about five, six years of fighting this, the unauthorized scam is pretty much near zero. The problem is the authorized scam. So here's a great investment, here's a beautiful Chinese girl. We'd like you to participate in a government sting operation, so transfer all your money to this secure account. So all these are factors associated with the authorized scam. And what do all these things have in common? They all exploit a human frailty. So you're talking about a problem that is actually taking advantage of the human condition, and therefore I come back to a core value system, trust and safety. So we are teacher trying to grow a digital future, a digital world, whether it's powered by underlying technological transformation, whether it's powered by AI, whether it's powered by the blockchain, and adversaries, bad actors are trying to exploit that. So it stands to reason that if we're going to fight this battle, it's not just the responsibility of the financial sector. In fact, I would extrapolate like this. Anybody who has an interest in profiting from their digital future has a corresponding and proportionate duty to protect that digital future. And by this, I mean telcos, I mean e-commerce providers, I mean social media providers, I mean OS manufacturers, I mean device manufacturers and so on and so forth.

(23:04):

The conversation therefore needs to be within your ecosystems, what is the limit of what you can do and how can you collaborate with the rest of the ecosystem. So every telco has to ask this question. Every social media company has to ask this question only by doing that should we make the future better. That would be my argument. And so honestly, that's what we're building here it DBS.

Ari Redbord (23:24):

No, absolutely. Obviously scams and fraud, couldn't agree more. We talk all the time about how we're at this really interesting point in the world and technology where the private sector has all of the data and you mentioned so much of it, the banks, the FinTech companies, the telecoms, the social media, and the government has all the authorities. And to me, it's figuring out how we can marry the data and the authorities. And that's we're thinking all the time about partnerships for disruption, interdiction, seizure, the Beacon Network, all this kind of thing. So I think I love how you're thinking about it and it's very, very similar. When I think about risks these days, I do think immediately about scams and fraud, about 30 billion last year in the crypto ecosystem. Other risk typologies that are sort of top of mind for you from the bank's perspective?

Chee Kin Lam (24:17):

I think we really have to also look at geopolitics, foreign policy and the relationships between countries. I think actually that is number one that sits above anti-money laundering and other types of risk typologies. I think the way we risk manage data and artificial intelligence needs just as much effort as we are putting into investments in tech infrastructure for powering AI. I saw a number of 700 billion, right? Sure. I'd love someone to add up the investments going to risk managing data and AI and what the number looks like. I do think the corresponding effort needs to go in there. As we talk about the development of markets, I

(25:01):

Think we always have to assume that bad actors are also trying to abuse the markets. I think that is a real risk that's in there. Conflicts of interest, I think that is also one of the things that reflects this. Maybe one more point I think is that it isn't a homogenous world. We are dealing with many, many different geographies and each of those geographies has their own version of public policy and considerations. And so the ability to make risk management decisions that cater to that amount of geographic diversity also is really critical. And I think there isn't a way to go one size fits all the way, nor is there a way to go hyper personalized geographic all the way. Neither of those approaches truly works. So you've got to come up with where you land in between, and that is also very difficult.

Ari Redbord (25:50):

One sort of question is that we got into a little bit with that last answer is, what do you see as the role of regulators? Really more as the system adapts and grows with the technological advances.

Chee Kin Lam (26:02):

So I move away purely from the role more to the responsibility. The governments make the public policy. The governments are the ones that task the regulators with implementing the public policy. The regulators take the ground up feelings and the feedback that comes from the ground and all the interested parties that are necessarily there, and they distill all that. So they have to come to this medium where they can discharge their public policy responsibilities, whether it's a growth mandate, whether it's a consumer protection mandate or whatever. They have to discharge the responsibility to the best extent that they can from, in a sense, also listening to the ground and modifying as appropriate. So I would say the most successful regulators can blend this really, really well. They don't go to one or the other. They don't let a populist opinion like they take public policy. And they don't just let the public policy decree in a sense be the end of the story.

(26:58):

There is a very, very healthy discussion around what is the right policy position to land on? How do we best implement this? How do we partner with the private sector to get our public policy objectives met, all these kinds of things? The regulators do that well, I think are the regulators that get a lot of, in a sense, regulation.

Ari Redbord (27:16):

Do you think that regulators over the last few years I think have understood the importance of engaging with the private sector in a more meaningful way? I certainly have seen that really across the world to include MAS, certainly.

Chee Kin Lam (27:31):

I think maybe right on my wheelhouse, which is the anti-money launding type of space. The whole discussion around PPPs, public-private partnerships to combat financial crime, that I think I would hold up as the poster child for how this approach has been absorbed. And yeah, we've got a lot to learn, but is it a whole lot better today than it was 30 years ago? Yeah, it's a whole lot better.

Ari Redbord (27:59):

And obviously such a huge focus for us and something I think about a lot is how we can leverage the technology to build those partnerships. I mean, only in blockchain can we and the regulators see exactly what's happening at the same time in real time, which is a pretty extraordinary thing we've never really been able to do before when you're talking about working directly with your regulator. So before I let you go, this was an amazing conversation. And again, thank you so much. We'd love to leave on a personal note, and that is when you're not thinking about some of the deepest issues in compliance and law and regulation, talk me through, what do you do for fun?

Chee Kin Lam (28:34):

Okay. So there are five things that really get me going. Happy to share this. And I think they've come out in one form or another in various, various public discourses over the years. I love my food. Doesn't matter whether it's cheap or expensive food. If it's what you eat when you go home or when it's what you eat when you go for lunch, I want to try that. Okay?

Ari Redbord (28:53):

Any amazing stories from that passion, like think places people have taken you or things you've tried?

Chee Kin Lam (28:59):

Oh yeah, yeah. From the highs to the lows. So if you've eaten a balut in the Philippines, you know exactly what I'm talking about. You know those kind of like the chicken eggs with the embryos Just about to hatch still beak and feathers and ... That's like a low light.

Ari Redbord (29:17):

Wow. Okay.

Chee Kin Lam (29:18):

But the highlights, and I'll say the Philippines as well, right? The highlights are when you really, really eat some homemade adobo, that is life-changing. A chicken pork, just the right amount of vinegar that's phenomenal.

Ari Redbord (29:33):

That's amazing.

Chee Kin Lam (29:34):

I love my drink as well. Not too much. I think we all know that. I love very, very fast cars that is inconsistent with drinking, so please be very checkful about it. Four thing, I love my computer games, a very, very avid pant and then fifting in a previous life, I would've been a rockstar in this life. I don't have the hair, I don't have the looks, but I still play a mean guitar.

Ari Redbord (29:57):

Oh, that's amazing. What do you play typically? Rock and roll?

Chee Kin Lam (30:01):

Yeah, typically alternative rock. If you're in university in the '90s in England, then pretty much it's Oasis, it's Smashing Pumpkins, the Manchester type of revival.

Ari Redbord (30:15):

That is so cool. Chiken, thank you so much for joining TRM Talks. This was an awesome conversation and really an honor to have you on.

Chee Kin Lam (30:23):

No worries. I had a lot of fun. Thanks, Ari.

Ari Redbord (30:29):

You know what's interesting, we've been having a lot of conversations within crypto and on TRM Talks about institutional adoption, really sort of what we're seeing from across traditional financial institutions in the United States, in Europe, and in Singapore, and across APAC. What really struck me about this conversation, which I thought was so cool, was it really went deep onto what has to happen from a compliance and legal side. A lot of times we're talking to the builders, we're talking about the business people. What is the business case for issuing a stablecoin for custody, for offering assets to customers? But here, we really went deep on compliance and what it takes conservative financial institutions to really lean into this space from a risk, compliance, legal perspective. I think that's really a huge takeaway for me here. On the next TRM Talks, I sit down with Anop Dattani from the West Midlands Regional Organized Crime Unit in the UK.

(31:26):

If you love the show, leave a review wherever you're listening to it and follow us on LinkedIn to get the latest news on crypto regulation, compliance, and investigations.

TRM Labs (31:37):

TRM Talks is brought to you by TRM Labs, the leading provider of blockchain intelligence and anti-money laundering software. This episode was produced in partnership with Voltage Productions. The music for this show was provided by iKOLIKS.

Ari Redbord (31:53):

Now, let's get back to building.