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Insight : ANTI MONEY LAUNDERING
ANTI MONEY LAUNDERING
Santander UK Plc - AML failures - £107m fine
There are extensive learnings for firms across all sectors and for all customer types. This checklist highlights the key issues identified in the Final Notice.....More
How to prevent AML failures
Analysing past AML failures can help firms shore up their own money laundering controls, writes Jake Plenderleith
South Africa edges towards FATF grey list
The Financial Action Task Force (FATF), alongside the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), assessed South Africa’s AML/CFT regime during an onsite visit in November 2019
Sharing the keys to effective collaboration in the fight against financial crime
Collaboration is increasingly viewed as an essential tool in the global fight against financial crime....More
Focus on professional enablers puts lawyers in spotlight
Increasing global regulation is putting the legal sector’s relationship with money laundering under the spotlight
Russia sanctions – so far
A revealing look at the impact of sanctions imposed upon Russian entities 6 months into the war in Ukraine.....More
Adaptability: An overlooked, and underrated, compliance skill
This Insight article explores the importance of adaptability as a soft skill for compliance professionals, focusing on the different types of adaptability skills, the reasons why adaptability is so important for compliance professionals and the ways in which to improve upon your adaptability.
Risk, Compliance and Cultural Change Series
This series on culture change will demonstrate how studying human behaviour can help alleviate some of the challenges of our profession, helping you, your colleagues and your firm.....More
How compliance can help prevent human trafficking
30th July is the United Nations World Day Against Trafficking in Persons, this article will look at what compliance professionals can do to help prevent this awful activity from happening
The smartest guys in the room – how to deal with cultural arrogance
Arrogance is an unpleasant trait to deal with in our career. It is, however, everywhere. Learning how and when to face it will be a long-term useful skill.....More
Mind your language
Words matter, as risk and compliance professionals it is vital that this is understood and acted upon. A misunderstanding can lead to a costly mistake so by understanding the nuances of language you can be better placed to communicate well with colleagues and stakeholders.
Financial crime within the metaverse
Criminals are always early adopters of new technology; it is up to compliance to ensure they do not gain a foothold in the metaverse.....More
Thumbs down: Fraud and social media
This Insight article focuses on the impact social media has had on the way fraudsters target their victims.
Why beneficial ownership is crucial in supporting current sanctions
Understanding who the owners of a company are is a key tool in fighting financial crime and potential sanctions evasion.....More
The dangers of money laundering within the art market
The value of the global art market has reached $67.4 billion so it is unsurprising that criminals have targeted it. Through understanding it’s vulnerabilities and what legislation is in place, compliance officers can help to prevent potential money laundering from happening.
Your questions, answered: Russia sanctions FAQs.
As governments continue to issue sanctions in response to Russia’s invasion of Ukraine, many firms are looking to limit their sanctions exposure. Our Russia sanctions FAQs consider the ways in which this can be achieved, as well as addressing some of the more complex demands placed on firms with Russian exposure.....More
5 considerations for a Transaction Monitoring system
Transaction Monitoring is an area that is constantly in the spotlight. The challenge for a financial institution is to get the balance right of monitoring the accounts of those individuals who are up to no good, but without impacting on the transaction flow of those who are innocent.
NFTs: the future, a craze or a risky business?
This Insight article focuses on the recent surge in popularity of NFTs, specifically detailing what NFTs are, the risks associated with them and what the future holds for the technology.....More
The big crypto conversation - MENA conference
The regulation of virtual assets will be high on the agenda at ICA Live: MENA, with a current and a former regulator driving the conversation.
Red flags for illegal wildlife trafficking
Identifying red flags in any form of transaction monitoring of customer activity is a key part of spotting and stopping criminal activity. This is crucial in trying to prevent the illegal trade of wildlife and this piece will highlight some of these red flags and discuss the important of good quality reporting when they are identified.....More
5 tips for handling SoF/SoW
Holly Thomas-Wrightson helps us to understand the complexities of source of funds and source of wealth.
Raising awareness of the illegal wildlife trade
Illegal wildlife trafficking has grown in its severity and occurrence in recent years. This article looks at how this has happened and the importance of building a solid criminal case against those that carry it out. Changing the behaviour of the consumer is a significant factor in the overall effort against the illegal wildlife trade and this article plays a large part in helping readings to understand the importance of this.....More
Happy Valentine’s Day – or is it?
Romance fraud is a crime that often avoids the headlines when compared to tax or credit card fraud, but it is on the rise and can leave victims with not just a loss of money but can also be a big hit to their self-esteem, if not very emotionally damaging. This piece will look at how it happens, how people can protect themselves and also what to do if you or someone you know has been a victim.
CPI 2021: Looking beyond a high score
The release of Transparency International's Corruption Perceptions Index (CPI) is always a significant event in the financial crime compliance calendar, compiling as it does a ranking of perceived corruption across countries around the globe. This year's index will make interesting, if dispiriting, reading for compliance professionals, and this piece argues of the need to look beyond the CPI to inform their own judgements based on curiosity and looking beyond the obvious.....More
A 2022 Compliance Wish List
This article recaps some of the developments we would like to see in the compliance world in the upcoming year
Pandora Papers - How to identify ultimate beneficial owners
The Pandora Papers were another massive story in 2021 as a group of journalists released a paper that highlighted the issue of UBOs. This have us a chance to reflect on the European regulatory landscape and best practice examples for financial institutions to enhance their systems and controls for preventing financial crime.....More
Why compliance needs to talk about sustainability
Recently, we conducted a poll of ICA members and the wider compliance community on sustainability and the role compliance has in addressing it. The results were not only revealing, but pointed to a potential new direction for compliance as its responsibilities expand.
Effective AML training: four questions to answer
Ensuring your employees are adequately trained in anti money laundering (AML) is a crucial component of managing financial crime risk. Not only is it vital to protect your firm, but its often required by regulations.....More
The importance of transaction monitoring – and the cost of getting it wrong
In this week’s #ICAInsight, Teodora Harrop considers what can be learnt from recent enforcement action and provides best practice examples from which firms can learn.
[Video] All you need to know about 6AMLD
In this video, James Wood-Rickett, Course Director, Global Lead - Anti Money Laundering, ICA, considers the key changes of 6AMLD.....More
UK sanctions – under new management
The UK has completed the process of leaving the European Union. This article is a follow up to a previous piece where the complicated relationship between sanctions and the UK’s transition from the EU was assessed. Here we will look at the reality of post-transition UK sanctions and the new sanctions landscape in the UK.
Cryptocurrency is complicated – but it’s not going away
Cryptocurrency has burst front and center onto the world stage, and we all need to better understand it and the technology behind it. This article will illustrate some of the challenges, even mysteries, of cryptocurrency and highlight the importance of everyone in compliance staying on top of it all.....More
Working together to stop money laundering
FATF President, Dr Marcus Pleyer, shared a vision for the future of AML at ICA’s BIG Compliance Festival
Top 10 reasons to be an MLRO
As a small child, how many of us dreamt of becoming a money laundering reporting officer? None, that’s how many. So, what makes the role of the MLRO today an attractive one? Here are the top ten reasons to take up the life of an MLRO.....More
3 tips on how to design financial crime training with impact
To change perceptions on training, a culture shift is needed to demonstrate to employees that training can not only be engaging but actually useful, enhancing their ability to carry out their role. How do you get employees to embrace training and, more importantly, use the knowledge and skills from this training in their daily roles?
How the art industry can adapt to the challenges of 5MLD
The most recent changes to the art market are significant. January 2020 saw the transposition of the EU Fifth Money Laundering Directive (5MLD) into UK law. After extensive consultation, and with HMRC as the regulator, art market participants (AMPs) face considerably more onerous anti money laundering (AML) requirements.....More
The future of AML frameworks – PPPs to the rescue?
Are current anti money laundering (AML) efforts sufficient to fight the evolving financial crime threat? Are they effective? What improvements can be made to AML frameworks? This is the first in a series of articles in which we will be asking profound questions of current AML practice, and presenting the case for a major rethink of AML regimes.
How COVID-19 brought out the best in society, the worst in criminals and an increase in identity theft
A crisis will bring out the best and worst of society and the current COVID-19 pandemic is no different. A crisis like this challenges us all to consider our actions and how we respond, this article looks at the positive ways that people have responded but also how criminals have sought to take advantage of it, in particular with the rise in identify theft.....More
Commerzbank’s FCA fine demonstrates danger of AML lapses
A comment on the fine imposed by the FCA on Commerzbank, and a discussion of the wider implications.
The changing world of anti money laundering
Current thinking around anti money laundering (AML) is flawed and is in desperate need of a rethink. The fundamental nature of money laundering, and how we combat it, needs examining.....More
Emerging TBML risks and how to manage them
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.
Shining a light upon our AML failings
The answer to being more effective at stopping money launderers is to challenge the value of processes that are clearly failing. Financial crime expert Martin Woods explains.....More
3 weaknesses that led to Malaysia’s 1MDB scandal
1MDB, the financial scandal linked to prominent figures in Malaysia, is under investigation in a number of countries, and those alleged to have committed crimes are slowly being brought to justice.
After 1MDB, Malaysia steps up its AML/CFT efforts
The cost of financial crime to the global economy is estimated at $1.45 trillion, according to Thompson Reuters report. Eye-watering even as an estimate, the figures are, however, no less alarming when broken down. In the Asia-Pacific region for example, financial crime is thought to cost local economies a combined $166 billion (unsurprising, perhaps, to those who have been following the 1MDB trial).....More
2020 will be uncertain and unpredictable. Here’s what compliance can do
Facebook’s tough few years symbolises the danger of underestimating risk. Compliance professionals can learn from the company’s mistakes to protect their own firms in an unpredictable environment in 2020.
Six steps to improve your customer due diligence
CDD is a key part of any firm’s anti money laundering and counter financing of terrorism (AML/CFT) framework. With this in mind, this blog looks at six steps that the reader can take to help improve their CDD.....More
Future proofing the compliance professional
Technology is set to have an impact on the way in which compliance professionals work. In a future defined by VUCA, what can compliance professionals do to ensure that they have the skills to prepare for the changes?
United Arab Emirates: the rapid pace of regulatory change
It is often said that the only constant in life is change, and that certainly rings true for the current regulatory climate. The global nature of financial crime means that all regulators, and firms operating in the regulated sector, must be quick to respond to threats.....More
How new technologies help prevent money laundering
$2 trillion – that’s the amount of illicit funds estimated to be laundered through financial institutions annually. Worse, financial crime appears to be increasing (see the latest from Insight for the reasons behind the rise). In response, Europol estimate that banks globally are spending $260 billion each year in financial crime defences to combat the issue.
Correspondent banking – why it's important to understand the risks
Money laundering scandals have been all over the news recently, with banks such as Danske and Swedbank....More
Irish stockbroker enforcement action: What were the issues and why do they matter?
On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbrokers
Why collaboration is vital to combat money laundering
Great strides forward have been made in the general awareness....More
Standard Chartered $1.1 billion enforcement action: what lessons can we learn?
It was announced that Standard Chartered has agreed to pay more than $1 billion to US regulators and the UK’s Financial Conduct Authority (FCA). What lessons can we learn from this?
The UK’s anti money laundering regime – A time for celebration?
Mutual evaluations from the Financial Action Task Force (FATF) are big news within the anti money laundering (AML) community; its peer reviews provide insight into the AML framework of a country, the key risks that it faces and how those risks are managed.....More
Skills and Attributes of an AML Professional - Infographic
Have you ever wondered which skills and attributes are useful when working in anti money laundering (AML)? If you currently work in AML, have you considered how your own skills measure up? Here’s a quick look at some of the skills and attributes that an AML professional may need
More focus required on professional money launderers
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
Getting the measure: the SMCR challenge
David Jackman highlights the challenges associated with efforts to measure whether the SMCR is working
Between the lines: The transformation of the AML landscape
The landscape of financial crime risk has been transformed in recent years with ever-increasing lapses in the anti-money laundering (AML) risk controls of global financial institutions.....More
Given ample opportunities, Canara’s inadequate action led to FCA fine
The £896,100 fine recently imposed on Canara Bank by the FCA is a useful example of the thinking behind penalties issued by the UK regulator.
Bitcoin and the ongoing money laundering risk
Cryptocurrencies, such as Bitcoin, will continue to challenge the way in which we conduct financial transactions - and ultimately how we tackle the issue of money laundering risk.....More
With a FATF visit looming, Hong Kong steps up AML/CFT efforts
FATF’s mutual evaluation in Hong Kong later this year will be its first evaluation in the territory since 2007.
EU fifth anti money laundering directive (5MLD)
Here’s an insight into some of the changes put forward in this fifth and latest update.....More
Are we becoming a cashless society?
Biometric technology, contactless cards and online shopping. Is this the beginning of the end for cash?
Why is it important to know your customer?
Do you ever truly know your customer? And, if you don't does it really matter?....More
Money Laundering & Financial Crime: Typology Update 2018
It’s been a few months since I last did one of these and wrote about the Pakistan Lottery Typology. There’s been a few things which have caught my eye since then so I thoughts I’d share them. No particular order. I’ll look at some similarities at the end though.
How many languages does a financial crime professional need to speak?
It seems not a day goes by at the moment without some mention of Bitcoin, cybercrime, political machinations, Brexit, global instability or the drivers of radicalisation, amongst other things. On top of this, there are even TV dramas about most of these subjects.....More
2018: elections, cybercrime, Bitcoin and bribery
Unpredictability is the new normal. What does 2018 hold for our industry?
The rise of the unregulated online gambling 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
Cryptocurrency prices and money laundering – Is there a link?
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?
The importance of tone from the top and why it should not be underestimated
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
Five things you need to know about Bitcoin
Bitcoin has taken the world by storm; Simone Jones shares what she has learnt about cryptocurrency over the course of the last year.
Everything you need to know about mobile financial services
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?....More
Why policy makers should shoulder responsibility for UK failings
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.
Blurring the lines: how technology is shaping illicit finance typologies
As technological innovation sweeps the financial sector, the compliance professional faces developments of huge consequence.....More
A turning tide? Terrorism and the Caribbean
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?
Money Laundering – the Pakistan Lottery Typology
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
Money Laundering and North Korea
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.
A closer look at Denmark’s anti money laundering efforts
Denmark sits at the enviable position as the ‘cleanest’ country in Transparency International’s Corruption Perception Index (CPI). As previously discussed in ICA Insights, although deemed to be the cleanest, Denmark isn’t free from all financial crime woes.....More
Combattre le blanchiment d'argent par la limitation des paiements en liquide
Avec Tracfin et certaines lois récemment instaurées, la France est un acteur européen majeur dans la lutte contre le blanchiment d’argent et le financement du terrorisme. Quels ont été les changements effectués lors de ces dernières années ?
Anti money laundering: a spotlight on Sweden
At the International Compliance Association, we regularly find ourselves deliberating money laundering issues, which can range from recent enforcement actions to newly published reports showing the latest figures for details such as suspicious activity reports or jurisdictional risk. Which is why, when I read a headline stating that the Swedish legal system was being exploited to commit money laundering, quite a discussion was sparked.....More
Are Bitcoin addresses shell companies in disguise?
Anonymity, discretion and confidentiality: terminology often associated with shell companies incorporated in jurisdictions with high secrecy laws. However, does the virtual economy – notably Bitcoin, the de facto currency of choice – facilitate the very same mechanisms that criminals attempt to abuse? This brief article will explore some of the key similarities between a shell company and a Bitcoin address, with a view to answering the question ‘Are Bitcoin addresses shell companies in disguise?’
New York: Leading the fight against crime
New York has been capturing the imagination and the attention of the world for well over 100 years. It’s a city like no other; its intoxicating pull is felt by both residents and non-residents alike. It has also long been a source of inspiration for those looking to fight crime: in the Superhero world, Marvel’s Spiderman, The Avengers and The Defenders all call New York home. Some people believe that Metropolis and Gotham, home to Superman and Batman, are also based on New York.....More
How effective is Ireland's AML system? An analysis of FATF Mutual Evaluation Report for Ireland
Ireland is an important regional and international financial hub and is included in the IMF’s 29 systematically important financial centres. This is evidenced in the sheer number of banks looking to move some of their operations from London to Dublin in the wake of Brexit.
Legal marijuana in Canada
You might be unaware that at around the same time, across the border in Canada, a taskforce was set up to provide recommendations on the outline of a framework for the regulation and legalisation of recreational cannabis in the country. A report was subsequently published which delineated these recommendations, exploring how cannabis should be regulated, minimum age requirements, personal allowance and packaging.....More
Fuzzy matching: Getting the balance right
Screening your entire customer base on a regular basis can alert you to the risk of being exposed to suspicious or sanctioned individuals and organisations, but how do you ensure that you are completing these searches effectively?
Biometrics, cash and the end of money laundering as we know it?
As the technology to facilitate cashless transactions becomes more widespread, it can play an important role in know-your-customer and anti-money laundering efforts.....More
Money Laundering Regulations 2017
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:
Why We Say Yes
Why would someone well educated and well compensated risk their own liberty to pay a bribe? Richard Bistrong covers the reasons why we say yes.......More
FIFA: The Beautiful Game?
Fifa, football's world governing body responsible for promoting and protecting the sport, has done more damage to the reputation of the game than any other organisation or individual.
FATF Mutual Evaluation Report – Sweden
Sweden is generally perceived as a safe country with low crime. It ranks near the top of international indices for low corruption and strong rule of law. Tax crimes are the most significant predicate offence for money laundering identified in Sweden’s national risk assessment (NRA). Fraud is also identified as a major and growing concern. Both offences contribute a large part to the proceeds of organised crime in Sweden.....More
The importance of transparency and challenging a collusive culture
Listen to Sally Scutt, ICA Strategic Advisor interview Annabel Reoch, UK Head Anti-Bribery and Anti-Corruption, KPMG about the importance of transparency and challenging a collusive culture.
Corruption: Perception and reality
ICT compares results from the World Economic Forum publishes annual corruption index and Transparency International's Corruption Perception Index (CPI) in this Prezi presentation.....More
How did we get here – an ABC of Anti Bribery and Corruption
There is a good chance that corruption is a subject of both personal and professional concern to you. If that is the case, it is a sentiment you share with individuals the world over.
Five key points of the upcoming Fifth Anti Money Laundering Directive (5AMLD)
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
Brexit, Fintech and Big Data: Joining the dots in Ireland
It is fascinating how apparently unconnected points can be linked to reveal compliance challenges and opportunities. How, for example, does Brexit connect us to AML regulations, FinTech and Big Data in Ireland?
Fake documents: For all your ‘novelty’ proof of address needs
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.....More
Is your client a money launderer?
Googled it? We offer insight to firms who vet their customers for ‘negative news’ or ‘adverse information’ through various methods of screening.
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