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.
As the UK leaves the EU there are some areas of legislation that will diverge from one another, sanctions is one of these. The UK adheres to both UN and EU legislation and once it leaves the EU framework it will be responsible for it’s own fate. With the transition period coming to an end, this piece will look at how the UK is preparing to strike its own path and the complexities involved in future relationships with the EU and other countries.....More
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.
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.
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?....More
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.
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.....More
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.
A comment on the fine imposed by the FCA on Commerzbank, and a discussion of the wider implications.....More
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.
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.....More
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.
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).
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.
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?
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
$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.
Money laundering scandals have been all over the news recently, with banks such as Danske and Swedbank....More
On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbrokers
Great strides forward have been made in the general awareness....More
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?
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
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
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
David Jackman highlights the challenges associated with efforts to measure whether the SMCR is working
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
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.
FATF’s mutual evaluation in Hong Kong later this year will be its first evaluation in the territory since 2007.
Biometric technology, contactless cards and online shopping. Is this the beginning of the end for cash?
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.
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
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
Bitcoin has taken the world by storm; Simone Jones shares what she has learnt about cryptocurrency over the course of the last year.
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
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.
As technological innovation sweeps the financial sector, the compliance professional faces developments of huge consequence.....More
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.
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
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…
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
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.
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
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.
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 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.
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
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.
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.
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
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...
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.
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
ICT compares results from the World Economic Forum publishes annual corruption index and Transparency International's Corruption Perception Index (CPI) in this Prezi presentation.
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
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.
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
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.
We break down combined fines of nearly £18 million issued by the Financial Conduct Authority to five top offenders in 2016.
A large number of global information, communication and technology (ICT) companies are based in Ireland.
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
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?
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
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.
A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.....More
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.
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
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).
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
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 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
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.
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
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.
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
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.
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 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 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 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.
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
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.
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
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.
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