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
In what has become something of a festive tradition at ICA, we’ve collated the biggest of these fines issued by both OFAC and the FCA this year to see what lessons can be learnt for 2020.
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.....More
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.
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?
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
Malcolm Wright, Chief Compliance Officer, Diginex, and keynote speaker at ICA’s 2nd APAC Conference, discusses the latest trends and challenges in virtual banking and how it’s impacting the skills and competencies of compliance professionals.
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.
At the recent City Week International Financial Services Forum in London, one of the panel sessions focused on the evolution of financial crime, and a statistic highlighted during the session struck a chord with me.
Human trafficking is one of the fastest growing and most widespread criminal activities in the world.....More
The Monetary Authority of Singapore details enforcement actions and key initiatives as it launches debut enforcement report.
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.....More
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.
When correctly motivated, employees remain honest and become the most effective frontline defence against the fraudster. Employees become motivated when they believe that:....More
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’.
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.....More
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.
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.
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....More
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.
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.....More
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.
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.....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.
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
We examine the case of automotive giant Volkswagen, the most recent household name to be hit by US authorities for breaching laws and regulations.
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
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.
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.....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 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
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.
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:....More
We awoke this morning to news that several FIFA officials had been arrested for corruption in ‘dawn raids’ at a Zurich hotel. I’m sure that we woke up a little more gently than those officials who had a knock on their hotel room door!
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).....More
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:-
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.
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.....More
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.
The Parliamentary Commission on Banking Standards was set up to look into professional standards and culture within the UK banking sector. Its recent report – "Changing Banking for Good" – puts forward several recommendations.....More
Financial Crime has recently emerged as a hot topic of late and I feel it is something that should be brought to the general public’s attention. Here in Singapore we are launching, for the first time in the region, the ICA Financial Crime qualifications, giving us a great platform to start looking at this area in a little more detail.
We’ve been covering the topic of “culture” extensively within inCOMPLIANCE. And with good reason – cultural change at banks is increasingly being acknowledged as a board-level strategic challenge, and one which the compliance community can make a positive contribution towards.....More
Bonus season is guaranteed to provide some talking points, and this year is no different.For many within the City, the award of massive payouts for those at the helm of major financial institutions is simply the cost of employing such “talent”; a relatively small price to pay given the massive demands of the job.
The range of threats facing organisations means there are a multitude of career option in financial crime prevention. From anti-bribery and corruption specialists, to fraud analysts and cyber security experts there are a variety of challenging and rewarding roles out there. The roles on offer are very diverse but all require a combination of technical knowledge, understanding of business processes, products and services and the key vulnerabilities targeted by financial criminals.....More
We have a problem. Money Laundering Reporting Officers must increasingly hit the highest standards of professionalism. This is a good thing.
After 40 years teaching and training in universities and professional bodies, I was recently asked a question by a student about how, after so much time, it was possible to maintain keenness and enthusiasm about the subject matter of the class.
So the UK FSA has published their Thematic Review of Anti-Bribery and Corruption (ABC). The lesson is clear. After a new law is enacted or a financial crime theme becomes the focus of regulators due to a scandal, there is a huge response and hype. When the dust settles firms must ensure that control frameworks are properly implemented, and they finish the job. We know the regulators will be watching.....More
TRMG has been working with Legal and General to produce that firm’s Digital Criminal 2012: CyberSafety report. One of the report’s key findings is that criminals are targeting social media users online by setting up fake profiles, ‘friending’ potential targets and then tricking them into giving up sensitive personal information. The information gleaned in this manner is being used to commit identity theft, fraud and to plan burglaries.
The BBC Business website has today added a video on PPI compensation levels. Most of you will know what PPI stands for, at least in the first instance - Payment Protection Insurance. But the second instance you may be less familiar with - Polly Peck International. So what’s going on, I hear you ask?....More
The Transparency International ‘Corruptions Perceptions Index’ published annually, offers a glimpse of global corruption based on perceived levels within the public sector of 183 countries. The Index is a funny thing, loved in some quarters and loathed in others, but still an interesting perspective on where various nations stand compared to others on the issue of corruption. Some results are not surprising; North Korea and Somalia are ranked joint bottom on the list.