Insight : ANTI MONEY LAUNDERING

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.....More

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.

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?....More

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.

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.....More

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

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....More

Why collaboration is vital to combat money laundering

Great strides forward have been made in the general awareness

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?....More

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.

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

How to use a football club to launder money

Identify a football club in distress

5 best practice tips for training in AML and Compliance

Increased regulatory expectations, rising standards and best practice now makes it clear that rapidly clicking through a computer based training course does not mean people have been given the right skills to tackle the complex issues facing regulated firms today.....More

Meet an ICA Member: Muhammad Rizwan Khan

Who are our members and what can we learn from them?

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

Anti money laundering and risk assessment in the gambling industry

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.

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?....More

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…

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.....More

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.

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 ?....More

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.

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?’....More

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.

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.....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.

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.....More

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.

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.....More

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.

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?....More

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.

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.....More

Top FCA Fines of 2016 Infographic

We break down combined fines of nearly £18 million issued by the Financial Conduct Authority to five top offenders in 2016.

Reviewed: 2016 Corruption Perceptions Index

Transparency International’s 2016 Corruption Perceptions Index was released this week, so we've taken a look at the more notable movements in this year's report.....More

Ireland, Technology and Integrity

A large number of global information, communication and technology (ICT) companies are based in Ireland.

Skills and Attributes of an Anti Money Laundering Professional

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?....More

Gibraltar and Brexit – Rock and a Hard Place?

Brexit has been a huge story all year, and will continue to be so throughout 2017 as Article 50 is triggered. Living and working here in the UK, I’m constantly bombarded with opinions telling me what the potential impact of leaving the EU could have on me and my family’s future. But what about the UK overseas territories? Gibraltar, for example, which, from memory, was the first region to declare their results from the EU referendum on June 23rd - voted an overwhelming 96% for the ‘Remain’ side. What are the implications of the overall result for this unique part of the UK?

Cyprus’s economic crisis: why effective GRC is essential

Numerous reasons have been cited for Cyprus’s economic collapse, but one of the most enduring has been the charge of weak corporate governance in Cypriot banks. The demise of the now defunct Laiki Bank, previously the second biggest bank on the island, is indicative of the weak Governance, Risk and Compliance (GRC) framework that existed across Cypriot financial and governmental institutions.....More

Ireland concerned Brexit will damage anti money laundering efforts

Britain’s referendum on withdrawal from the European Union sent convulsions across Europe, and the uncertainty that the decision to leave triggered across the continent is felt nowhere more keenly than in Ireland. The Irish National Risk Assessment on Money Laundering (ML) and Terrorist Financing (TF) makes this explicitly clear; Brexit makes up a third of the ML/TF risk-enhancing factors for the Irish state.

Our top seven Switzerland blogs on money laundering, terrorist financing and beneficial ownership

A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.....More

Beneficial ownership: A new era of openness? (United Arab Emirates)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive (4MLD), and the central registers of beneficial owners that it will introduce.

Fraud in Switzerland - an update on high profile fraud related stories

We don’t know who originally had the idea for committing financial crime, although what is said to be the first recorded incident of fraud – involving a Greek merchant called Hegestratos, an upfront payment for transporting a cargo of corn and a failed plan to scuttle the ship carrying it – dates back to around 300 BC.....More

Warning to banks in Hong Kong

The Monetary Authority of Singapore launched a dedicated anti money laundering (AML) department on 1 August, and this triggered my interest in reading more about AML-related developments in Asia Pacific. I came across an article from May this year which talked about how regulators in Hong Kong, for example the Hong Kong Monetary Authority (HKMA), are cracking down on trade based money laundering (TBML).

The BCCI Scandal

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.....More

Infographic: ICA Open Day - 13 September 2016

Still wondering whether to come to the ICA Open Day (or one of the local sessions)? Then have a look at our infographic for a few compelling reasons to register your place this year...

The FCA Anti-money laundering annual report 2015/16: progress – and challenges

The UK’s Financial Conduct Authority (FCA) has published a small library of reports this month, including its Anti-money laundering annual report 2015/16, which provides some interesting insights into its work, and some themes emerging from this, over the last year.....More

Top 5 Money Laundering Cases of the Last 30 Years

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.

The FCA Annual Report: taking a closer look

Here in the UK, after weeks of blanket media coverage around Brexit, a change of Prime Minister and the legal complexities involved in the Labour leadership election, we could be forgiven for wanting a change of subject matter. So the Financial Conduct Authority’s (FCA) Annual Report for 2015/16 could provide a welcome respite for financial services professionals, though it’s not exactly what you might call light reading.....More

Football, mobile phones and money laundering

Bright ideas are the lifeblood of any business or organisation. The same applies to money launderers, who always seem to be coming up with new techniques of their own, or abusing entirely legitimate systems and technologies, in order to stay a step ahead of law enforcement and other authorities.

Life after the referendum: terrorist financing high on FATF agenda

Here in the UK, there’s not much on our news agenda apart from the EU referendum outcome and the resulting fall-out, so significant developments elsewhere in the world since 23 June have perhaps been slipping under our radar.....More

Reporting Suspicions of Money Laundering and Terrorist Financing: Spotlight on the Netherlands

At the International Compliance Association, we regularly find ourselves discussing money laundering and related issues. The reporting of suspicious transactions is a topic that often crops up and we’ve recently done some work around different reporting regimes around the world, how figures from different countries compare, whether national challenges are similar and if there are similarities in the entities submitting the highest number of reports. As a result, I took a closer look at the Netherlands.

Anti-Corruption Conference raises corruption awareness and there’s no room for complacency

The UK-led Anti-Corruption Summit held in London earlier this month attracted some significant publicity, much of which focused on David Cameron’s inadvertent remark that Nigeria and Afghanistan were ‘fantastically corrupt’.....More

Beneficial ownership: A new era of openness? (The Netherlands)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept that seems guaranteed to attract a great deal of international interest over the coming months and years, not least because of the European Union’s Fourth Anti-Money Laundering Directive (4th AMLD) and the central registers of beneficial owners that it will introduce.

Beneficial ownership: A new era of openness? (Sweden)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept that seems guaranteed to attract a great deal of international interest over the coming months and years, not least because of the European Union’s Fourth Anti-Money Laundering Directive (4th AMLD) and the central registers of beneficial owners that it will introduce.....More

Beneficial ownership: A new era of openness? (Gibraltar)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive, and the central registers of beneficial owners that it will introduce.

Panama Papers: Offshore Leaks Database

The international Consortium of Investigative Journalists has now released an Offshore Leaks Database, further lifting the secrecy from thousands of offshore entities from its Panama Papers investigation and its 2013 Offshore Leaks expose. Here's some of what it reveals.......More

All change on cash? Tackling money laundering through cash transaction limits in Switzerland

A good way to get an eye-catching headline these days is to carry out some research predicting the death of cash, now that we are all abandoning notes and coins in favour of smartphone apps, contactless cards and mobile payments.

All change on cash? Tackling money laundering through cash transaction limits in Germany

A good way to get an eye-catching headline these days is to carry out some research predicting the death of cash, now that we are all abandoning notes and coins in favour of smartphone apps, contactless cards and mobile payments.....More

All change on cash? Tackling money laundering through cash transaction limits in France

A good way to get an eye-catching headline these days is to carry out some research predicting the death of cash, now that we are all abandoning notes and coins in favour of smartphone apps, contactless cards and mobile payments.

Beneficial ownership: A new era of openness? (Germany)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive, and the central registers of beneficial owners that it will introduce.....More

Beneficial ownership: A new era of openness? (Switzerland)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive (4MLD), and the central registers of beneficial owners that it will introduce.

Beneficial ownership: A new era of openness? (France)

Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive, and the central registers of beneficial owners that it will introduce.....More

Reporting Suspicions of Money Laundering and Terrorist Financing – The German Perspective

Reporting Suspicions of Money Laundering and Terrorist Financing: Spotlight on France

We started discussing suspicious transaction reporting regimes around the world, wondering how the UK's figures compared to other countries, whether the challenges were similar and if there were similarities in the entities submitting the highest number of reports. This led to my taking a closer look at what was happening in France.....More

Reporting Suspicions of Money Laundering and Terrorist Financing – A Closer Look at Switzerland

At the International Compliance Association we find ourselves discussing money laundering issues almost constantly. One of the reasons that I love my job is that I get to discuss the finer points of anti money laundering regulations with other like-minded people.

The Senior Managers Regime - what are your priorities?

Several months ago we carried an article in our magazine InCompliance about the new Senior Manager and Certification Regime....More

Implementation Day presents a shifting sanctions landscape

“Implementation Day” – the lifting of sanctions following Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) – came around more swiftly than some had anticipated at the time that the JCPOA was initially agreed. Anyone not expecting compliance to be achieved so rapidly will be feeling the pressure to get fully up to speed with this new landscape.

Infographic: ICA Open Day - 3 February 2016

Still wondering whether to come to the ICA Open Day (or one of the roadshows)? Then have a look at our infographic for a few compelling reasons to register your place this year....More

Infographic: Don't Look Won't Find - Transparency International Report Statistics

Billions of pounds in corrupt funds are pouring into the UK every year. Transparency International - Don't Look Won't Find Weaknesses in the supervision of the UK's anti money laundering rules.

Single Criminality vs Dual Criminality

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?....More

Single Criminality vs Dual Criminality

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?

OECD: tax and anti money laundering bodies need to step up joint working

Joined-up thinking is something it’s hard to argue against. But while it’s a great idea in theory, co-operation, communication and collaboration don’t always materialise on an in-house basis, let alone where different organisations are involved, even if they are pursuing similar aims.....More

Threat of “KYCC” highlights need for joined-up approach to financial inclusion and financial integri ...

“There is a risk of setting a ‘know your customer’s customer’ standard for the whole global system,” Anders Borg, former Swedish Finance Minister, has warned.

South Asia: Reserve Bank of India fines and anti-bribery law amendments

The Reserve Bank of India, the national banking regulator, has issued INR1.5cr (USD165,276) fines to three public sector banks and issued to cautions to eight more for failure to implement appropriate measures to prevent and detect AML/CTF. The censure comes in the wake of a thematic review of KYC in banks which found a lack of due diligence carried out in public sector banks and a concerning use of intermediaries to open and operate accounts.....More

Terrorism and the UK - Did you realise?

"The figures for assets frozen are remarkably low..."

Banks – between a rock and a hard place?

Yesterday the Financial Conduct Authority in the UK released a statement of their expectations of Banks’ management of money laundering risk:....More

Lobbying: fostering a culture of integrity

There is a serious shortfall in transparency, integrity and equality of access within the lobbying process across Europe, according to a report released last week by Transparency International. This has created a need to “foster a culture of integrity among companies and organisations seeking to influence public policy,” says TI.