Deepa Chandrasekhar considers the significance of the recent OFAC decision to sanction cryptocurrency exchange Suex
The political fallout has been described as ‘the biggest diplomatic crisis in transatlantic relations since the Iraq War
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.....More
This blog series will explore sensitive questions around whistleblowing. It will consider the social and individual processes that surround deviant corporate behaviour and why these are strong barriers to ‘speaking up’. It will also ask how we can bring those barriers down. A field operation plan for whistle-blowers will also be built, sharing techniques that individuals can adopt to assist them in the face of corporate misdemeanours.
Throughout this mini-series, we have explored how compliance faces unprecedented challenges and exciting new opportunities in our rapidly changing, digitising world.
A recent roundtable, sponsored by Wolters Kluwer and organised by ICA, looked at the importance of balancing machine learning (ML) and artificial intelligence (AI) with human intelligence and intervention.
An effective GRC practitioner must face problems rather than avoid them, hold to principles when it is easier to dodge them and challenge commonly accepted beliefs when needed. What psychological research tells us is that these qualities do not come naturally to us as humans.....More
We are already seeing signs that the 2020s will be vastly different from the 2010s and unrecognisable in many ways from, say, the 1980s. Back then, a ‘job for life’ was a reality and a career within a single profession or trade, perhaps even with the same employer was common place. These days, rather than seek a job for life, Generation Z are more likely to question how they can leverage their value now and start their own business or, at least, a side hustle. This article will explore these differences and look at how compliance could be reimagined in the future and who is best suited for a role within this burgeoning industry.
A recent roundtable on best practice for risk assessment, sponsored by OneTrust and organised by ICA, uncovered some fascinating insight from those on the front line of compliance.....More
Outside of our profession, a common frame of reference for compliance is the historical context of enforcing rules and regulations
Share your input into a short survey about your organisation’s approach to sanctions control
Curiosity is not often seen as an attractive trait: as the saying goes ‘curiosity killed the cat’. But for compliance professionals, I would argue that it is a key skill we need to improve both personally and professionally, and in order to protect our firms from risk.
Over the last five years, there has been a significant shift in the sanctions world, from traditional jurisdictional and list-based sanctions to those that are more nuanced and thematic.....More
As ESG disputes against financial institutions heat up, financial institutions must improve their governance, risk management processes, policies and disclosures.
In a rapidly changing digital world, thinking around compliance needs reframing. The question today is whether compliance can keep up in world moving faster than any had thought possible
When a compliance professional perceives their pay package may be reduced as a result of their actions, there is a risk of biased decisions
A global panel of experts with law firm Gibson Dunn share insights around recent anti-corruption developments in some of the world’s largest regions, including China, India, Latin America, and Africa.....More
In this report, Onfido analyses data from its roster of global clients to understand where current and future risk lies
What is the real value and benefit of training to the modern compliance professional?....More
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 a global organisation, we understand that diversity and inclusion is different around the world - the challenges faced by different groups vary significantly.....More
Most people understand and accept that human decision-making is tainted by bias. But what is less well-understood is how these human biases can creep into technology intended to streamline, improve or make fairer decisions made by machines.
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.
We asked nine prominent chief compliance officers what they can do or are doing to create a more progressive workplace.
Experts offer best practices on how to ensure your D&I policies, training, and resources are sufficient at this social and cultural inflection point.....More
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?
This free to download e-book by Galvanize explains how technology can improve your regulatory and policy compliance
Job loss, financial difficulties, health concerns and change of personal circumstances are some of the by-products of the current pandemic affecting the public.
Today, more than ever before, compliance professionals must contend with myriad challenges including rapid digitisation, technological disruption, fast-moving regulatory change, and new forms of risk. As a result, their capabilities are coming under increased scrutiny, with many asking the question: how does the skillset of the modern compliance professional need to evolve for the function to be successful?....More
The three lines of defence model is an important way of managing risk within a business. If you're working in the second line and have recently moved to the first line, you could find this a daunting experience.
On International Women’s Day, we caught up with Angelia Lee, Sandra Horma and Alice Chen, who were on a 'women in compliance' panel at the 2nd Annual APAC Conference last year. They share their great insights, experiences and advice for other women in the compliance industry.
The Basel Committee of the Bank for International Settlements recommends the CAMELS rating system as an early warning mechanism for the assessment of the overall soundness of banks.
The role of the compliance officer has changed. Typical compliance responsibilities – interpreting regulations and legislation, creating policies and advising various business areas of their compliance requirements – remain fundamental, but as compliance develops so do the requirements for a compliance officer.....More
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.
The compliance career path has never been a straight line. It’s not like medicine, for example, where you know early on you’re going to be spending a lot of time and money learning to become a doctor. And once you become one, you spend the rest of your working days practising medicine.....More
The UK’s data regulator, the Information Commissioner’s Office (ICO), has issued guidance to help organisations explain their use of — and reliance on — artificial intelligence (AI) in decision making and how such technology might impact the public.
Download your free copy of Dun & Bradstreet's latest e-book ‘Busting The Myths That Make Third-Party Risk Management More Painful’ published in association with ICA....More
Compliance professionals employed in SRA-authorised law firms should be busy preparing to support their colleagues to make a safe and appropriate transition.
‘Vulnerable Customers’ is not a topic you can avoid if you are a compliance professional in the retail sector. While the UK may be leading in the implementation of new requirements, many other jurisdictions are incorporating or considering the principles involved. These principles are pretty much incontrovertible and so there is inevitable pressure and momentum behind development of this area.....More
Fresh legislative initiatives and large scandals are thrusting whistleblowing on to the corporate agenda. However, how companies approach internal whistleblowing arrangements varies significantly across Europe. This is according to the Whistleblowing Report 2019 published by the University of Applied Sciences HTW Chur in Switzerland and EQS Group.
Virtual currencies, cybercrime and Trumponomics, to name just a few, present interesting dilemmas: to what extent should we be conversant in these areas in order to fully understand the financial crime risks associated with them?
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
The new Transparency International Corruption Perceptions Index (CPI) has been released and you can see the results here. The Index is used in many financial crime models and is a highly regarded tool for geographic risk insight.
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
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.
Collecting all the information required to manage your compliance programme is not only time consuming but can be costly. So, how exactly do we propose to make this less painful?
You could be forgiven for thinking that the Senior Managers and Certification Regime (SMCR) is old news – been there, done that, move on to the next thing. This could well be the case if you work in the banking sector, but for the rest of the financial services fraternity it is most definitely up there on the ‘things to do’ list.
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
It struck me that the compliance department has certain parallels with the Ministry of Magic from J.K. Rowling´s Harry Potter series. Both are often misunderstood, mysterious, ‘secretly’ structured but at the same time necessary and important.
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…....More
Openness and transparency are considered as “vital parts of Swedish democracy” and all those principles of freedom are reflected in some fundamental laws which govern the Swedish constitution.
Since 2008, the UN has held its day in honour and promotion of democracy on 15 September. For a cluster of nations across Latin America, this is a date that holds a special reverence, marking their independence from colonial rule: Guatemala, El Salvador, Honduras, Nicaragua and Costa Rica all celebrate their independence day on 15 September (with Mexico’s the following day, and Chile’s three days later).....More
Since 2008, the UN has held its day in honour and promotion of democracy on 15 September. For a cluster of nations across Latin America, this is a date that holds a special reverence, marking their independence from colonial rule: Guatemala, El Salvador, Honduras, Nicaragua and Costa Rica all celebrate their independence day on 15 September (with Mexico’s the following day, and Chile’s three days later).
Technological innovation is ceaselessly impacting on many key sectors of our lives, and the financial industry is not immune to it. European institutions are aware that technology-enabled and technology-supported financial services (FinTech) represents a great opportunity for the financial industry.....More
It’s not just a question of following a rule book, compliance officers need to be able to strike a good balance between commerciality and compliance.
Distributed ledger technology (DLT) – of which blockchain is one particular type – is a decentralised database. This means that instead of records being held by one trusted entity that is the true source of the information (which is how many databases operate at the moment in the form of a ‘centralised ledger’), a group of peers maintain a shared database. Therefore, the consensus of the group is the record: there is no single trusted source.....More
This weekend sees the annual English FA Cup Final. It’s been previously reported that this football match can attract half a billion viewers from across the world. Chelsea won the English Premier League this season. This was widely lauded as being down to a switch to a 3-5-3 formation in the early autumn. Arsenal have often utilized 4-3-3 formation. The ‘3 lines’ seems to dovetail rather nicely with the ‘3 lines of defence’ mode (3LOD), which is widely used in regulated firms to provide a systematic approach to risk management. Let’s explore that a bit further so we can draw out the similarities.
Panama, Brazil, Afghanistan, China, Malaysia, Pakistan, Ukraine, Angola, South Africa. Examples of corruption cases abound beyond the limits of European geography. A cursory look at the Transparency International Corruption Perception Index shows plenty of low-ranking jurisdictions, many situated at a substantial distance from continental Europe. Does this mean that European companies, executives, regulators and prosecutors can sit back, head early for the beaches of the Mediterranean this summer and leave their international counterparts to manage these anti-corruption risks far from Madrid, Paris, Rome and other EU capitals? Clearly, the answer is ‘no’.....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...
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.
In a recent ICA article, we addressed the issue of de-risking and in particular the effect this is having in the Caribbean. The article referred to the fact that the United States are mostly responsible for the de-risking drive, and I want to highlight some of the indicators of this and also to look at why the U.S. are taking this approach.....More
Have you ever wondered which skills and attributes are useful when working in compliance? If you currently work in compliance, have you considered how your own skills measure up?
Modern slavery is a global issue that takes many guises and has the capacity to impact on businesses across many industry sectors.
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.
The President-elect of the United States is a man on more familiar ground on Wall Street than in Washington DC, and yet Donald Trump will surely be focusing his attention on the banks when he moves into the White House in January.....More
The Netherlands has a long history of navigating the world and trading with other countries. Trade creates wealth and is a vehicle to spread new knowledge and best practices. But trade also raises tremendous risks, especially in regions outside Western Europe and the United States.
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
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.
Governance, Risk Management and Compliance (GRC) have been shown to be interconnected concepts. Applied effectively in a business, they can reduce costs, cut inefficiency and improve communication throughout an organisation; GRC can help ensure a businesses’ goals and objectives are better defined, the company structure improved and regulations properly adhered to. Indeed, strong GRC lays the foundations for potential company growth.....More
Sweden was the first country in the world to introduce freedom of the press as a constitutional right in 1766. This long tradition included the principle of freedom of information, giving both the general public and the mass media access to public records.
A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.....More
German companies have developed a complex supply chain integrated by thousands of third parties, subsidiaries and agents worldwide. As the strategic importance – and Compliance risks - of third parties increases, companies have to mitigate business risks while building trust in their partners.
German companies have developed a complex supply chain integrated by thousands of third parties, subsidiaries and agents worldwide . As the strategic importance – and Compliance risks - of third parties increases, companies have to mitigate business risks while building trust in their partners.....More
Corruption can be defined as ‘Dishonest or fraudulent conduct by those in power’ and usually falls into three main categories: grand corruption, petty corruption and political corruption, which the anti-corruption campaign organisation Transparency International defines more specifically.
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