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.....More
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.
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.....More
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.
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).
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.
Ten years ago, the Middle East was a different place to the one that we see today. You only have to look at a picture of the Dubai skyline in 2008 and compare it to the current one to appreciate the aesthetic changes that have taken place. But it has not only changed aesthetically: the regulatory progress in the region’s financial sector has been equally discernable.....More
When correctly motivated, employees remain honest and become the most effective frontline defence against the fraudster. Employees become motivated when they believe that:
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
An amendment to the Sanctions and Anti Money Laundering Bill was approved by the British government in May. The headline news from the amendment was that from 2020 British Overseas Territories (BOT) will be obliged to publish the beneficial owner(s) of all registered companies.
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).
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.....More
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.
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
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?
At the beginning of this year, the ICA published the top Financial Conduct Authority (FCA) fines of 2016. So as we come to the end of 2017, I thought we’d take a look at who’s been on Santa’s naughty list this year; in other words, the top FCA fines of 2017.....More
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.
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.....More
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.
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.
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.....More
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.
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?....More
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.
In order to achieve good understanding of, and compliance with, your anti-corruption policies, you need a process that transfers the necessary knowledge, insight and skill to those who serve your organisation.
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.....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...
As this is Anti-Corruption week, I thought it would be good to take a look at the top ten fines handed down to companies under the Foreign Corrupt Practices Act (FCPA).
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.....More
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.
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.
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.....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.
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.....More
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’.
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?
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.
Odebrecht and Braskem, two Brazilian companies, have been fined at least US$3.5 billion after pleading guilty to bribing government officials.
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?....More
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.
A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.....More
Where would we be without technology? It has become a fundamental part of many of our daily lives.
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
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.
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
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.
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.....More
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.
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.....More
The Panama Papers have truly put the cat among the global pigeons. What the rich, powerful and famous from around the world have been secretly getting up to offshore makes fascinating reading and the revelations have already toppled one prime minister.
A debate is currently raging between the industry, policymakers, and regulators. The stakes are high indeed with the industry arguing disproportionate regulation could lead to hugely increased costs (in the millions of pounds) and job losses across the high street retail betting shop sector.....More
LIBOR, conspiracy to defraud, the Bank of England, Barclays, Qatar, dual criminality and some other observations…….
Today feels quite significant to me. Not only has it been a week since I took up my role within the Research and Development team at International Compliance Training, but also very importantly, it’s International Anti-Corruption Day.
If there’s a gap in the market, you can guarantee that some bright spark will fill it. The same ingenuity also thrives in financial crime. The high-tech world we live in is the perfect breeding ground for new types of threat to emerge. As in the classic Whac-A-Mole game, as soon as one threat is knocked on the head, another is almost certain to pop up somewhere else.....More
I came across an article recently that reported on a money laundering conviction in Thailand in which a Dutchman, Johan van Laarhoven, received a prison sentence of 103 years. Now, on the face of it Van Laarhoven elicits no sympathy from me, if you’re involved in money laundering you deserve to face the consequences, right?
I finished my previous blog by saying that it would be interesting to see how the FIFA case develops - perhaps on reflection a comment on the patently obvious! Now the initial media frenzy has settled down it gives us a chance to review the allegations.....More
The final report of the Fair and Effective Markets Review (FEMR) was published last week. Commissioned in response to the series of scandals that have blighted the fixed income, currency and commodities (FICC) markets, the Report’s account of the shortcomings that led to such scandals is depressingly familiar; a combination of:
Swiss prosecutors have announced that $380 million is to be returned to Nigeria as funds linked to the ex-dictator Sani Abacha. General Sani Abacha assumed the leadership of Nigeria in 1993 following a coup d’état. During his five year rule he was estimated to have stolen up to $5billion (TI, 2004).
It seems HSBC are never out of the headlines at the moment, and the detail becomes more incredible each time (allegedly the Chief Executive’s bonuses were paid to an anonymous Panamanian holding company and then kept in a Swiss bank account).....More
A leaked memo* has revealed that in five years’ time, all personal and commercial transactions in the broader EuroZone will have to be undertaken electronically, using facial recognition identification technology.
A topic that is high on the agenda in our discussions around the future of banking. Are we actually seeing the ‘seismic shift’ that has been suggested? Having attended the recent BBA Conference on Digital Banking I have been giving a lot of thought to the subject and reviewing what I see as the key points that came out during the day:-....More
South East Asia is about to become borderless; someone is keeping tabs on the North Korean leadership apparatus and campaign financing is under the spotlight.
2014 has so far been a year of massive regulatory fines. The US authorities in particular have upped the ante in their actions against large financial institutions. Amongst the highest profile of these was the $9bn fine issued against BNP Paribas in July, which led recently to the resignation of the bank's chairman, Boudouin Prot.....More
Last week, India’s Prime Minister Narendra Modi hit the headlines with his promise of bank accounts for every household in the country, a bid to offer help to the country’s poor. The initiative is part of a movement towards financial inclusion, which means making financial services accessible by people who do not have formal identification documents, fixed abodes or even known dates of birth.
In May 2013 Barclays said it would close the bank accounts of Somali remittance company Dahabshiil and a number of other money transfer companies (between 100 and 250 depending on what you read). This was a considered decision as part of Barclays’ risk-based approach to its obligations under UK anti-money laundering legislation.....More
As you will know if you’ve been reading this blog for the last year or so, I’m not averse to the odd film reference. I also have an interest in some of the subcultures we highlight in our courses. So I thought I’d combine the two and draft a plot for a film. Picture the classic Container Port scene in Heat and you’re on the right track.