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
This article recaps some of the developments we would like to see in the compliance world in the upcoming year
This article is the second in our series on sanctions: What it takes to work in sanctions compliance....More
Times and technology may change, but the fundamental means by which criminals attempt to launder money and carry out their nefarious acts are still rooted in the same criminal process – commit a crime, evade capture and benefit from the proceeds.
Are you inadvertently contributing to criminality? As we acclimatise to the ‘new normal’, we examine how the global pandemic has helped facilitate unprecedented growth in the UK’s counterfeit market and how compliance professionals utilise their skills to combat it.....More
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.
Many aspects of life over the last year have stagnated as a result of the COVID-19 pandemic, with the virus grinding whole countries and economies to a halt. However, one thing that defied the slowdown – depressingly – was the number of human trafficking victims.....More
A fascinating collection of global industry insights on current and emerging trends, challenges and opportunities in 2021 and beyond
Wildlife trafficking is a big issue. We’re not just talking about endangered animals from Africa being poached and sold on the black market. There are many other ways that wildlife trafficking can be a part of your life, without you even realising it.....More
The nexus between transnational organised crime and terrorist financing is a contentious, ongoing topic of debate. The extent of their connection is disputed, but what is accepted is that the motivation and ideology of a terrorist differs fundamentally from that of organised criminal groups.
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.
2020 has been a year that most of us would gladly forget. Nevertheless, as we look towards 2021, it is worth considering the lessons learned over the last 12 months, assessing the evolving landscape, and (where possible) drawing on any positives that have come to light. This article considers some of the main features of fraud in 2020 and highlights potential trends for the coming year.....More
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.
Absorbing bribery and corruption statistics provided by the UN is, even during gentler times, a sobering experience. This year’s figures were as bold and quietly unsettling as ever, in a neat symmetry of the year itself. But the accompanying comments by UN Secretary-General did offer something new.....More
This e-book will reveal how money launderers target life insurance to their advantage, and how professionals working within the sector can prevent and detect it, bringing benefits to your organisation and the wider society.
This e-book considers 5 questions that can help when designing immersive scenarios for your team, from understanding the audience to creating scenarios that full realistic and resonate with learners.....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.
It is generally acknowledged that great strides forward have been made over the last decade in the fight against money laundering and financial crime. Few, however, would claim that there remains little to be done. But a remarkable new report by BAE Systems demonstrates just how far we have to go.....More
In the wake of the FinCEN Files leaks, Martin Woods examines whether monitoring text rather than numbers in transactions could serve as a solution to our greater anti-money laundering woes.
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.
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
Anti-bribery and corruption (ABC) is a high priority for compliance professionals in all businesses, indeed all areas of life. We have witnessed the “Feds Indict Footballing Aristocracy” within the investigation of the institutional bribery and corruption practices routinely applied by FIFA.
Crises rarely announce themselves in advance, and the COVID-19 pandemic is no exception. Criminals, always unscrupulous, have seized the opportunity presented to them by the pandemic to exploit new technologies and existing products and services to carry out their illicit activities.....More
Italy, a region in quarantine, is experiencing a spike in attempted cyber-attacks to capture the login credentials of employees working remotely during the coronavirus pandemic. But not all the attacks have been successful, and that’s where the lessons lie.
Identifying suspicious activity is both a regulatory requirement and a business imperative. However, it can be an extremely resource intensive, and consequently expensive, exercise. A system that is both effective and efficient can therefore bring significant regulatory and cost benefits.....More
Sanctions are a really useful tool in global politics, but they aren’t perfect. This insight article explores four ways that sanctions could be improved and made even more effective in their design and implementation.
One of the tools used to understand corruption risk is the Corruptions Perceptions Index (CPI), published on an annual basis by Transparency International, who work globally in leading the fight against corruption. The 2018 CPI, published in early 2019, ranked 180 countries in terms of how corrupt their public services are perceived to be, on a scale of 1 (highly corrupt) to 100 (very clean).....More
Offers of gifts or hospitality can be legitimate business practices, allowing relationships to be enhanced and built; but a line exists between appropriate business practice and illegal activity.
A proven and effective method of preventing terrorism is disrupting the financial networks used to fund it. This has been known to organisations, regulators and governments for some time now.....More
A brief comparison of the key outputs from the Office of Financial Sanctions Implementation's (OFSI) annual reports
Art and antiquities looting was ISIS’s second highest source of income at the terror group’s height. Unique and rare objects from the world’s oldest civilisations were flogged to Europe and North America to raise funds for its activities. The regulatory response from the EU and the art industry has been swift – but is it enough?....More
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.
Broadgate Search sat down with Pekka Dare, Director of Training Education and Development at ICA, to uncover various case studies in the financial sector.
Move over Bitcoin and Blockchain – there’s a new raft of terminology to come to terms with in the form of virtual assets, crypto-derivatives and Libra. Adding to the mix the recent announcement on virtual assets from the Financial Action Task Force (FATF), it’s been a busy few weeks for anyone keeping an eye on the virtual world. In this Insight piece we will be looking at four key updates from recent weeks.....More
Hands up if you’ve ever bought a fake pair of sunglasses or fake handbag? Or if you know someone that has? Maybe a friend of a friend has sold you a copy of a film on DVD?
Human trafficking is one of the fastest growing and most widespread criminal activities in the world.
The Monetary Authority of Singapore details enforcement actions and key initiatives as it launches debut enforcement report.....More
Take a moment to look beyond the turbulence of current affairs and traverse the terrain of a global anti-corruption trends monitor. What you will see, may surprise you.
Despite significant investment in compliance, we still see incidents where things go wrong. In many cases the root cause is the wrong culture and values. How do you drive the right culture across your organisation? How do you ensure everyone is accountable for compliance matters? Below we provide some tips to help support a successful compliance ‘change programme’.....More
US politics inevitably tends to attract greater scrutiny than anywhere else in the Americas. Regrettably, this often obscures that which is unfolding in the southern half of the continent, where very interesting – often odd, sometimes distressing – events are taking place. Last year was a case in point.
As Father Christmas prepares his list of who has been naughty or nice, I thought it would be interesting to take look at enforcement action in 2018 from around the world and consider some New Year’s resolutions that compliance professionals may want to make in 2019.....More
Christmas – the season of gifts and giving. Nobody needs reminding that we already hurtling our way full speed towards the Big Day, but for businesses it is the time of year when a useful reminder on the dangers of bribery is required.
Carlos Ghosn has his own comic book, The True Story of Carlos Ghosn. It ran as a strip in the manga Big Comic Superior in Japan in 2001, before being published as a book the following year. In a country obsessed with comic books, Ghosn having his own should give you an idea of the reverence in which he is held for reviving the ailing carmaker Nissan after his arrival in 1999.....More
Guy Fawkes Night celebrates the failure of the Gunpowder Plot to kill King James I at the Palace of Westminster on November 5, 1605. There’s something modern, and therefore something we recognise, in the Gunpower Plot: it featured a small group of fanatics, whose plan was wildly ambitious, violent, and spectacular in its execution
In August this year, the Financial Action Task Force (FATF) published a new report that aims to raise awareness and provide an updated and more precise understanding of the financial flows related to human trafficking.....More
Over the last decade the general public has woken up to the environmental issues affecting the planet. Concerted global efforts are now in place to reduce harm caused by pollution and to cut back on waste. The cost of cleaning up the damage already inflicted is now a central focus of national governments. Below, we look at the cost of financial crime and the incredible impact its prevention could have.
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
Biometric technology, contactless cards and online shopping. Is this the beginning of the end for cash?
In the wake of the Criminal Finances Act 2017, what is the future of financial crime policy management? Within the realm of financial crime policy management, there is an established and traditional approach to responding to legislative evolutions. As required by regulations, the first and fundamental step is the establishment and maintenance of policies, controls and procedures to mitigate and manage risk (UK Money Laundering Regulations 2017).....More
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
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?
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
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.
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.....More
Earlier this year the French government enacted Sapin II, an anti-bribery and corruption law that bolstered the country’s transparency and anti-corruption efforts. The legislation was introduced after criticism over the years of France’s anti-bribery and corruption efforts from several quarters (including the OECD). The introduction of Sapin II was the most significant initiative on anti-corruption in the country in decades.
In this comprehensive report, it was revealed that the biggest obstacle to investment in technology is cost. We have broken down the key findings of the report into this infographic, to help you understand the need for forward planning.....More
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 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
A decade-long battle between the United States government and the owners of a New York skyscraper was concluded last month when a US jury agreed with the government’s assertion that the Alavi Foundation, the majority owners, were guilty of money laundering and violating sanctions on Iran.
The successful infiltration of technology into every aspect of our personal lives has led pundits, over the last few years, to try and predict how technology will alter the landscape of our professional lives.....More
South Africa is undoubtedly a success story, from its lush wine lands which produce world class wines, diamond mines producing gems sold all over the world, to the Kruger National Park, which is populated by big game and is a huge magnet for tourists. South Africa seems to have it all, so why is its leader getting it so wrong? And what effect could this have on how the country is perceived around the world?
Bribery and corruption is a global issue, generating increasing public outcry and requiring international coordination. The direction of travel is clear – anti-bribery and corruption (ABC) is – finally - firmly on the agenda of government agencies, non-governmental organisations, media outlets and the public.....More
Interview with Peter van Veen, Director of the Business Integrity Programme and Rachel Davies Teka, Head of Advocacy, Transparency International
The use of sanctions as an international means of affecting change has grown exponentially in recent times. As countries become less and less keen to use military force, the world has turned to sanctions implementation as a means of impacting international change, both politically and socially.
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.
Asia and the rest of the world has been rocked by the 1MDB corruption scandal which has seen investigations triggered around the globe including the United States, Singapore, Switzerland, the United Kingdom, Hong Kong and Malaysia.
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
Historically, there hasn’t been a large number of high profile enforcement actions in relation to bribery. The low numbers could be taken as a sign that regulators are not focusing on this risk or conversely that firms have improved systems and controls so much that bribery is a thing of the past.
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
In January this year, the Office for National Statistics released its latest Crime Survey for England and Wales (CSEW). The CSEW is a face-to-face victimisation survey where individuals resident in England and Wales are questioned about their experiences of a selection of offences in the last 12 months. This survey - which covers October 2015 to September 2016 – includes for the first time the offences of fraud and computer misuse (also known as cybercrime). Although the CSEW is unable to compare the results for fraud and cybercrime to previous years, the figures are still pretty staggering.
The recent Serious Fraud Office (SFO) case against Rolls-Royce has prompted discussion on whether prosecutors should do more to hold individuals to account for bribery and corruption offences. CorruptionIn a guest blog for Transparency International, Sue Hawley of anti-bribery site Corruption Watch called the SFO’s deferred prosecution agreement (DPA) with Rolls-Royce a ‘failure of nerve’.....More
We examine the case of automotive giant Volkswagen, the most recent household name to be hit by US authorities for breaching laws and regulations.
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?....More
We break down combined fines of nearly £18 million issued by the Financial Conduct Authority to five top offenders in 2016.
The Financial Action Task Force (FATF) released this month their first Mutual Evaluation of the United States since 2006.
Odebrecht and Braskem, two Brazilian companies, have been fined at least US$3.5 billion after pleading guilty to bribing government officials.....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?
The insurance market is a dynamic sector offering increasingly sophisticated products to its customers and providing competition to other parts of the financial services industry. The insurance sector’s growth is particularly noticeable with some jurisdictions reporting a doubling of premiums in the last decade.....More
A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.
Where would we be without technology? It has become a fundamental part of many of our daily lives.....More
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.
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
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.
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.
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.
It’s all focus on France at the moment. A few weeks ago it was widespread strike action which was grabbing the world headlines as protests against reform of the French labour code caused significant disruption across the country. And now, with the 2016 European Football Championships progressing towards its conclusion, the Tour de France will be hot on its heels showcasing the beauty and variety of the French way of life.....More
Tous les yeux sont tournés vers la France ces derniers temps. Il y a de cela quelques semaines, les grèves générales suite à la proposition de réforme de la Loi Travail ont perturbé le pays et fait les gros titres. Aujourd’hui, la fin de l’Euro de football approche et c’est le Tour de France qui prendra bientôt le relai et exposera la « manière de vivre à la française » aux yeux de tous.
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