As I left a bright and sunny London yesterday afternoon having attended the Chatham House conference titled ‘Combating Global Corruption, Sharing Standards and Common Practice’ and shared the company of the good and the wise, I left encouraged because of the very considerable efforts that are evidently being made by law enforcement and other interested parties to reduce the demand and supply side of graft and corruption, but equally concerned by the apparent lack of action and regulation of alternative money transfer arrangements.
Throughout the past two days I have learned of the honest endeavour of law enforcement and the government here in the UK, the US and the Cayman Islands to combat corruption, and of the commendable efforts of private groups such as Ipaidabribe.com in India who are taking real action to close the door on corruption, a door that has permitted a polar wind to blow for far too long mostly but not exclusively from the emerging and frontier markets of the world.
I learned that there are a considerable number of people diligently applying themselves to uncover, report and to reduce the threat of the scourge of bribery and corruption sometimes risking their own safety and welfare, but also reflected upon the slow and seemingly reluctant steps that are being taken to establishing registers of beneficial ownership.
But ultimately, I was left concerned. Concerned that more than twenty years after the disclosure of bribery and corruption that was conducted by Sani Abachi we are still uncovering grand corruption (most recently James Ibori) and that the incorporation of shell companies and misuse of nominee directorships remains a matter that has still not yet been resolved.
As gamekeepers we must anticipate and respond to the threat posed by the poachers. By the time that these new measures are implemented, technological innovation and the development of digital currencies that is already supporting value transfer outside of the mainstream regulated banking sector (think of Silk Road and Liberty Reserve), may in any case make these measures largely irrelevant when they are introduced.
Whilst acknowledging that the international virtual currency flow is still small when compared to established banking transaction flows, it is nonetheless a growing and rapidly evolving market and the risk continues to be a blind spot to may organisations, indeed jurisdictions. It was therefore more surprising that this risk was not mentioned throughout the conference until the matter was raised in the very last question that was asked by a delegate at the close of the final day.
I cannot help but be concerned that the gamekeepers may be too fixated on addressing a risk that is current and which they are more familiar with, namely the transparency of beneficial ownership of companies created to confuse and disguise the money trail, whilst neglecting that the poachers are already moving well beyond our current and familiar boundaries to a new field. A field for which there is entirely insufficient regulatory reform and regulation at the present time, and which judging by the response to beneficial ownership controls over the last twenty years, will not nearly be adequately remedied for some time to come.
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