COVID-19 represents a special challenge for all organisations. As well as exacerbating existing concerns, it has ushered in a slew of new ones. If these issues are to be successfully addressed, firms need to understand new and existing risks that pose a threat to business.
Today, more than ever before, compliance professionals must contend with myriad challenges including rapid digitisation, technological disruption, fast-moving regulatory change, and new forms of risk. As a result, their capabilities are coming under increased scrutiny, with many asking the question: how does the skillset of the modern compliance professional need to evolve for the function to be successful?....More
Anyone with Compliance responsibilities will know you need a wide range of interpersonal skills to be resilient, successful and effective. The secret is to improve your emotional intelligence. Two sample podcasts are available here and provide small bursts of practical advice of relevance in the current climate.
ICA's regular webinar series presenter and author of the ICA Specialist Certificate in Anti-Corruption, Penny Milner-Smyth, is the featured guest on the Great Women in Compliance (GWIC) podcast.....More
On International Women’s Day, we caught up with Angelia Lee, Sandra Horma and Alice Chen, who were on a 'women in compliance' panel at the 2nd Annual APAC Conference last year. They share their great insights, experiences and advice for other women in the compliance industry.
Blockchain is capturing the imagination of the financial services for its potential to reduce risk and decrease costs. It’s easy to consider blockchain as a unicorn – elusive, never seen and no one seems to quite know its capabilities. Blockchain is a type of distributed ledger technology (DLT), but what exactly is blockchain and DLT? And how can they be used by mainstream companies?....More
When it comes to customer due diligence (CDD) - what challenges do AML professionals in financial institutions face?
Virtual currencies, cybercrime and Trumponomics, to name just a few, present interesting dilemmas: to what extent should we be conversant in these areas in order to fully understand the financial crime risks associated with them?....More
When correctly motivated, employees remain honest and become the most effective frontline defence against the fraudster. Employees become motivated when they believe that:
The CMA and the ICA are collaborating to ensure that together we can #StopCartels....More
Live events, done well, can be unparalleled for learning and professional growth. So who is speaking at the Big Compliance Conversation: Singapore Conference?....More
When asked to consider IWT, many people would think of ivory and tiger skins; but it is so much more than that. IWT can be broadly defined as ‘any action which contravenes current legislation (nationally or internationally) governing the protection of animals and plants’ (NPCC).
Inconsistent laws, political tension and ambiguous banking regulation. What next?
The Financial Action Task Force (FATF) has recently produced a report looking at the ways in which individuals and organisations, known as professional money launderers (PMLs), are charging fees or commission for providing a money laundering service to criminals.....More
The FATF’s International Cooperation Review Group (ICRG) identified four key areas of concern in respect of Pakistan; can these be resolved?
French firm Lafarge, a major producer of cement, construction aggregates and concrete, is the subject of a formal investigation by French authorities over allegations of terrorist financing, violating international sanctions and committing crimes against humanity.....More
A recent Guardian article has found the cashless approach to be increasingly popular, particularly with businesses in the food and drink sector it seems. Where does that leave pounds, shilling and pence?
The World Cup has got off to an explosive, entertaining start. We follow up our coverage of each team’s first fixture with Part 2 of our World Cup of Corruption, looking at each nation’s ranking on Transparency International’s 2017 Corruption Perceptions Index. Teams included in Part 2 include Sweden, Senegal, South Korea, Panama, Poland and Japan.....More
Football itself – and in particular FIFA – has been beset by corruption problems over the last decade. In light of this we thought we would consider each fixture of the tournament through the lens of corruption.
In 2015, an agreement, known as the Joint Comprehensive Plan of Action (JCPOA), was drawn up in which Iran agreed to curtail its nuclear activities in return for the lifting of UN, US and EU sanctions.
An amendment to the Sanctions and Anti Money Laundering Bill was approved by the British government in May. The headline news from the amendment was that from 2020 British Overseas Territories (BOT) will be obliged to publish the beneficial owner(s) of all registered companies.
What is trade finance and is it really as high-risk as it is often perceived?
The FCA’s business plan for this year has had to strike a careful balance between the considerable amount of work that is going to be taking place on Brexit, which is already well underway, and their other strategic priorities.
RegTech is now one of the most talked about innovations in the financial services sector. The added influx of FinTech that has caused the incumbent population of the financial services industry to sit up and take notice. Disruption is a clear and present threat to this community. The revolution is here.....More
For the first time, we are delighted to offer our Diploma graduates the opportunity to recertify their qualification in either AML, governance risk and compliance or financial crime prevention.
One of the most frequently asked questions is ‘will an ICA qualification get me a job?’. This hardly comes as a surprise.
Over the past months, the world has witnessed a rise of an unprecedented global movement against sexual harassment and assault. It's time to rethink what constitutes a harassment-free workplace environment and revisit your anti-harassment policies, fostering a cultural shift in attitudes to this issue.....More
Unpredictability is the new normal. What does 2018 hold for our industry?
Should the anti-money laundering (AML) community be concerned at the prevalence of such Bitcoin services, and their open lack of regard to customer due diligence (CDD) controls?....More
As Bitcoin prices rose from $1,000 to $19,000, Ethereum from $8 to $715 and Ripple XRP up from $0.0064 to $3.79 in under 12 months, I found myself wondering, can this all be true? What is the story behind these obscene gains? Is this a wonder drug promising immortality to mankind?
As firms continue to navigate the labyrinthine minefield of legislation and regulation and claw their way up the evolutionary ladder of compliance with standards that appear to have moving goal posts, ‘tone from the top’ has never been more important.....More
The five-hour rule has become synonymous with inspirational leaders around the world. What is it and who abides by it? Bill Gates? Yes. Barack Obama? Double yes. Oprah? You guessed it, yes. The five-hour rule is a relatively new term, but one that is perfect for explaining success. Whatever your personal opinion of the aforementioned leaders, their success is undeniable.
Over the last decade, mobile financial services (MFS) have been instrumental in increasing financial inclusion in developing markets. What impact does this have on financial services and the telecommunications industry?
In November 2017, Transparency International (TI) published the report Hiding in Plain Sight which further highlighted the attractiveness of UK Plc to those that wish to launder the proceeds of corruption or value of other criminal origin.....More
As technological innovation sweeps the financial sector, the compliance professional faces developments of huge consequence.
At the beginning of this year, the ICA published the top Financial Conduct Authority (FCA) fines of 2016. So as we come to the end of 2017, I thought we’d take a look at who’s been on Santa’s naughty list this year; in other words, the top FCA fines of 2017.....More
What exactly is required of a KYC analyst? What are the specific duties and responsibilities that make up this key compliance function?
As the year draws to a close, it’s always a good opportunity to reflect on the past 12 months. With this in mind, I took a look back at the blogs International Compliance Training has published on anti money laundering in 2017 and chose my five favourites.....More
The UK Government recently published their strategy for addressing the effects of corruption across the UK, which will provide a framework to guide the government’s anti-corruption policies and actions. It also underpins the current government’s strengthened focus on economic crime. We thought we’d take a look at some of the key elements.
I wrote in June about an increased regulatory focus on AML within the gambling industry. This included reference to requirements set out within the GB Gambling Commission’s licensing regime that entail the preparation of money laundering risk assessments (MLRA) by all gambling operators. This new condition mirrors an existing obligation for casinos to develop such assessments – required by the Money Laundering Regulations and recognised internationally as a fundamental component of successful AML capability. During my time within the Gambling Commission, and since then, delivering AML training, I have found that no issues cause more confusion and uncertainty than the nature and development of operator ML risk assessments. Whilst this short piece won’t provide a comprehensive explanation, it can serve to de-mystify some of the elements.....More
In the lead up to the UN’s International Anti-Corruption Day on 09 December, we have collated a collection of articles and blogs, written over the last 12 months, to aid your learning journey on this all-important subject. The information that you take away should help stimulate discussion and support you in making sound decisions in your role.
It struck me that the compliance department has certain parallels with the Ministry of Magic from J.K. Rowling´s Harry Potter series. Both are often misunderstood, mysterious, ‘secretly’ structured but at the same time necessary and important.....More
Thanksgiving Day is upon us, and in celebration of the annual harvest, we have collated our top five blogs with US origins. Let’s take a retrospective look at our favourite blogs from the last year, with a keen focus on the United States.
How many of us, if we were then asked to think of terrorism and the Caribbean, would think back to the bygone era of piracy; of Calico Jack and mutiny on the seas? This era ended around the 1830s so surely terrorism is something that now happens outside of the Caribbean, doesn’t it?....More
Jerry Walters has a Distinction in the International Compliance Association Diploma Course in Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF). As well as being a member of the ICA, Jerry is a former Detective Constable and has worked on high profile cases including Operation Trilby. He is still involved in all aspects of tackling financial crime through the running of his own business. Here, Jerry discusses what ICA and compliance means to him.
Hooray! I’m a winner! I won £412,000 on the Pakistan Prize Bond Draw. And I didn’t just win it once. I won it 123 times. Yes – you read that correctly. I won it 123 times. Fancy that eh? What an incredible run of luck. Now pause, if you haven’t already. That’s as likely as winning the UK National Lottery jackpot 40 weeks running…....More
I read an article recently that highlighted how North Korea is using Hong Kong to launder their criminal proceeds. The article described the use of shell companies established in the region that provide the Democratic People’s Republic of Korea (the official name of North Korea) with access to the global financial system. Severe international sanctions are in place to restrict this access to North Korea, so any advantage they can gain is really important for them to maintain the best access they can.
On Monday 26 June 2017, by the skin of its teeth, the UK enacted the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs 2017). Dragging its heels, somewhat unusually for UK Plc, there were a few tweaks but no real surprises between the draft MLRs and the final version with five key changes made:....More
We get asked a lot of questions about ICA qualifications. That makes sense given our role as a training provider. The questions range from ‘will this qualification land me a new role?’ to ‘what course is right for me?’. While we are always happy to have a chat about options and suitability, and make recommendations, fundamentally the qualification you select has to be your decision.
What is the 5AMLD? 5AMLD is a bit of misnomer, as it is in fact a set of proposed amendments to the Fourth Anti Money Laundering Directive (4AMLD) which is to be transposed on 26th June 2017. These proposed amendments were published in July 2016 as a way of strengthening the 4AMLD in light of recent terrorist attacks in Europe.....More
The Internet has brought us many great things, but I would argue that easy access to counterfeit documents is not one of them. Over the years we have seen the emergence of websites offering creation of fake documents – you send the name and address you want shown on a bank statement or utility bill, along with the transactions, and they create it for you.
Verifying the identity of a customer can be as gloriously simple as meeting a customer face-to-face and taking a copy of their original passport and a utility bill. On the other side of the client due diligence (CDD) spectrum is trying to unravel a complex corporate structure and understanding the identity of the ultimate beneficial owner.....More
Have you ever wondered which skills and attributes are useful when working in compliance? If you currently work in compliance, have you considered how your own skills measure up?
Have you ever wondered which skills and attributes are useful when working in anti money laundering? If you currently work in AML, have you considered how your own skills measure up?
“Tell me and I forget, teach me and I may remember, involve me and I learn.” ― Benjamin Franklin. At ICT, we are passionate about learning and development and tens of thousands of individuals and firms all over the world have realised their training ambitions through us.....More
After reading the comments on my previous blog on some of the biggest money laundering cases of the last 30 years, I have been inspired to look into one of those cases in more detail. The case involved the Bank of Credit and Commerce International, or BCCI, and it has made for very interesting reading.
Money laundering and, conversely, anti money laundering (AML), continues to be a hot topic, especially within businesses and large corporations, as government agencies – particularly in the US (where an estimated £231 billion is laundered annually) – continue to crack down on money laundering and sanctions violations.....More
I came across an article recently that reported on a money laundering conviction in Thailand in which a Dutchman, Johan van Laarhoven, received a prison sentence of 103 years. Now, on the face of it Van Laarhoven elicits no sympathy from me, if you’re involved in money laundering you deserve to face the consequences, right?
Can you guess where this quote is from? The quote in itself is beautiful, don’t you think? It is not from Einstein, or Socrates, or even Gandhi who all have attributed to them great sayings about learning and wisdom. This quote is actually from B.B. King American blues singer and musician, who sadly died last week. For me, this quote encapsulates everything about why people engage in a journey of learning, it is more to do about something within you rather than something outside of your control. Because the reality of it is that once you embark on a course of study, for example a degree, or a postgraduate course or diploma of some sort, only you can determine the success of achieving that goal.....More
For those of you who are based in a country where we offer workshops as part of your course, here are a few hints and tips on how you can maximise your workshop experience.
In May 2013 Barclays said it would close the bank accounts of Somali remittance company Dahabshiil and a number of other money transfer companies (between 100 and 250 depending on what you read). This was a considered decision as part of Barclays’ risk-based approach to its obligations under UK anti-money laundering legislation.....More
When I go to briefing sessions about ICA qualifications and speak to delegates about their career aspirations , one of the more frequent questions I get asked is “will the qualification get me a job in the area I am interested in?” Indeed in the last two or three years this question has increased significantly in popularity due to the rise in recruitment opportunities in compliance and related roles.
Is your firm identifying and reporting the appropriate level of suspicious activity in respect of money laundering? For many of the firms and AML professionals that I speak to the answer is a clear no.....More
The range of threats facing organisations means there are a multitude of career option in financial crime prevention. From anti-bribery and corruption specialists, to fraud analysts and cyber security experts there are a variety of challenging and rewarding roles out there. The roles on offer are very diverse but all require a combination of technical knowledge, understanding of business processes, products and services and the key vulnerabilities targeted by financial criminals.
Up to 1 Billion USD$ in fines. Group Head of Compliance David Bagley quits. Huge reputational fallout and remedial action required. A disastrous scenario for HSBC, and a time for all working in anti money laundering to take stock. What are the lessons to be learnt.....More
One question that I have often been asked during my compliance career, and that comes up quite regularly in workshops is “what exactly is the difference between compliance and audit?”
One question that I have often been asked during my compliance career, and that comes up quite regularly in workshops is “what exactly is the difference between compliance and audit?”....More
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