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Virtual Currencies – four key updates in 2019


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

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How new technologies help prevent money laundering


$2 trillion – that’s the amount of illicit funds estimated to be laundered through financial institutions annually. Worse, financial crime appears to be increasing (see the latest from Insight for the reasons behind the rise). In response, Europol estimate that banks globally are spending $260 billion each year in financial crime defences to combat the issue.

Correspondent banking – why it's important to understand the risks


Money laundering scandals have been all over the news recently, with banks such as Danske and Swedbank....More

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Irish stockbroker enforcement action: What were the issues and why do they matter?


On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbrokers

Why collaboration is vital to combat money laundering


Great strides forward have been made in the general awareness....More

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Monetary Authority of Singapore launches debut enforcement report


The Monetary Authority of Singapore details enforcement actions and key initiatives as it launches debut enforcement report.

Standard Chartered $1.1 billion enforcement action: what lessons can we learn?


It was announced that Standard Chartered has agreed to pay more than $1 billion to US regulators and the UK’s Financial Conduct Authority (FCA). What lessons can we learn from this?....More

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What are the 6 benefits of studying for an ICA qualification?


Whether you’re new to the industry or taking the next step in your career, it’s important to choose the best compliance training possible. We have put together the top benefits of studying for an ICA qualification & advancing your career.

Which ICA qualification is right for me?


This is the question we get asked the most. With ICA Briefing Sessions in full swing at the moment, it seemed like it was worth addressing. So what do we tell you? Essentially, there are two main pieces of advice we normally focuse on when discussing ICA qualifications....More

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The UK’s anti money laundering regime – A time for celebration?


Mutual evaluations from the Financial Action Task Force (FATF) are big news within the anti money laundering (AML) community; its peer reviews provide insight into the AML framework of a country, the key risks that it faces and how those risks are managed.

Skills and Attributes of an AML Professional - Infographic


Have you ever wondered which skills and attributes are useful when working in anti money laundering (AML)? If you currently work in AML, have you considered how your own skills measure up? Here’s a quick look at some of the skills and attributes that an AML professional may need....More

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How to use a football club to launder money


Identify a football club in distress

[Infographic] FATF Reports in Brief: Human Trafficking Infographic


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

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A look at the illicit financial flows from wildlife crime and illegal wildlife trade


When asked to consider IWT, many people would think of ivory and tiger skins; but it is so much more than that. IWT can be broadly defined as ‘any action which contravenes current legislation (nationally or internationally) governing the protection of animals and plants’ (NPCC).

Meet an ICA Member: Muhammad Rizwan Khan


Who are our members and what can we learn from them?....More

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More focus required on professional money launderers


The Financial Action Task Force (FATF) has recently produced a report looking at the ways in which individuals and organisations, known as professional money launderers (PMLs), are charging fees or commission for providing a money laundering service to criminals.

Pakistan added to FATF Grey List


The FATF’s International Cooperation Review Group (ICRG) identified four key areas of concern in respect of Pakistan; can these be resolved?....More

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Given ample opportunities, Canara’s inadequate action led to FCA fine


The £896,100 fine recently imposed on Canara Bank by the FCA is a useful example of the thinking behind penalties issued by the UK regulator.

With a FATF visit looming, Hong Kong steps up AML/CFT efforts


FATF’s mutual evaluation in Hong Kong later this year will be its first evaluation in the territory since 2007.....More

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EU fifth anti money laundering directive (5MLD)


Here’s an insight into some of the changes put forward in this fifth and latest update.

How high risk is trade finance?


What is trade finance and is it really as high-risk as it is often perceived?....More

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Are we becoming a cashless society?


Biometric technology, contactless cards and online shopping. Is this the beginning of the end for cash?

Why is it important to know your customer?


Do you ever truly know your customer? And, if you don't does it really matter?....More

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The rise of the unregulated online gambling industry


Should the anti-money laundering (AML) community be concerned at the prevalence of such Bitcoin services, and their open lack of regard to customer due diligence (CDD) controls?

The importance of tone from the top and why it should not be underestimated


As firms continue to navigate the labyrinthine minefield of legislation and regulation and claw their way up the evolutionary ladder of compliance with standards that appear to have moving goal posts, ‘tone from the top’ has never been more important.....More

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Everything you need to know about mobile financial services


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?

Why policy makers should shoulder responsibility for UK failings


In November 2017, Transparency International (TI) published the report Hiding in Plain Sight which further highlighted the attractiveness of UK Plc to those that wish to launder the proceeds of corruption or value of other criminal origin.....More

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Blurring the lines: how technology is shaping illicit finance typologies


As technological innovation sweeps the financial sector, the compliance professional faces developments of huge consequence.

Top five blogs on anti money laundering of 2017


As the year draws to a close, it’s always a good opportunity to reflect on the past 12 months. With this in mind, I took a look back at the blogs International Compliance Training has published on anti money laundering in 2017 and chose my five favourites.....More

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Anti money laundering and risk assessment in the gambling industry


I wrote in June about an increased regulatory focus on AML within the gambling industry. This included reference to requirements set out within the GB Gambling Commission’s licensing regime that entail the preparation of money laundering risk assessments (MLRA) by all gambling operators. This new condition mirrors an existing obligation for casinos to develop such assessments – required by the Money Laundering Regulations and recognised internationally as a fundamental component of successful AML capability. During my time within the Gambling Commission, and since then, delivering AML training, I have found that no issues cause more confusion and uncertainty than the nature and development of operator ML risk assessments. Whilst this short piece won’t provide a comprehensive explanation, it can serve to de-mystify some of the elements.

A turning tide? Terrorism and the Caribbean


How many of us, if we were then asked to think of terrorism and the Caribbean, would think back to the bygone era of piracy; of Calico Jack and mutiny on the seas? This era ended around the 1830s so surely terrorism is something that now happens outside of the Caribbean, doesn’t it?....More

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Meet an ICA Member with Jerry Walters


Jerry Walters has a Distinction in the International Compliance Association Diploma Course in Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF). As well as being a member of the ICA, Jerry is a former Detective Constable and has worked on high profile cases including Operation Trilby. He is still involved in all aspects of tackling financial crime through the running of his own business. Here, Jerry discusses what ICA and compliance means to him.

Money Laundering and North Korea


I read an article recently that highlighted how North Korea is using Hong Kong to launder their criminal proceeds. The article described the use of shell companies established in the region that provide the Democratic People’s Republic of Korea (the official name of North Korea) with access to the global financial system. Severe international sanctions are in place to restrict this access to North Korea, so any advantage they can gain is really important for them to maintain the best access they can.....More

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A closer look at Denmark’s anti money laundering efforts


Denmark sits at the enviable position as the ‘cleanest’ country in Transparency International’s Corruption Perception Index (CPI). As previously discussed in ICA Insights, although deemed to be the cleanest, Denmark isn’t free from all financial crime woes.

Combattre le blanchiment d'argent par la limitation des paiements en liquide


Avec Tracfin et certaines lois récemment instaurées, la France est un acteur européen majeur dans la lutte contre le blanchiment d’argent et le financement du terrorisme. Quels ont été les changements effectués lors de ces dernières années ?....More

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Anti money laundering: a spotlight on Sweden


At the International Compliance Association, we regularly find ourselves deliberating money laundering issues, which can range from recent enforcement actions to newly published reports showing the latest figures for details such as suspicious activity reports or jurisdictional risk. Which is why, when I read a headline stating that the Swedish legal system was being exploited to commit money laundering, quite a discussion was sparked.

Be a learn-it-all


CEO Satya Nadella made the news last year when he revealed the secret of improved culture at Microsoft over the last few years has been down to the embracing of a learn-it-all culture.....More

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Fuzzy matching: Getting the balance right


Screening your entire customer base on a regular basis can alert you to the risk of being exposed to suspicious or sanctioned individuals and organisations, but how do you ensure that you are completing these searches effectively?

Biometrics, cash and the end of money laundering as we know it?


As the technology to facilitate cashless transactions becomes more widespread, it can play an important role in know-your-customer and anti-money laundering efforts.....More

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Five key points of the upcoming Fifth Anti Money Laundering Directive (5AMLD)


What is the 5AMLD? 5AMLD is a bit of misnomer, as it is in fact a set of proposed amendments to the Fourth Anti Money Laundering Directive (4AMLD) which is to be transposed on 26th June 2017. These proposed amendments were published in July 2016 as a way of strengthening the 4AMLD in light of recent terrorist attacks in Europe.

Brexit, Fintech and Big Data: Joining the dots in Ireland


It is fascinating how apparently unconnected points can be linked to reveal compliance challenges and opportunities. How, for example, does Brexit connect us to AML regulations, FinTech and Big Data in Ireland?....More

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Is your client a money launderer?


Googled it? We offer insight to firms who vet their customers for ‘negative news’ or ‘adverse information’ through various methods of screening.

Skills and Attributes of an Anti Money Laundering Professional


Have you ever wondered which skills and attributes are useful when working in anti money laundering? If you currently work in AML, have you considered how your own skills measure up?....More

Cyprus’s economic crisis: why effective GRC is essential


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.

Ireland concerned Brexit will damage anti money laundering efforts


Britain’s referendum on withdrawal from the European Union sent convulsions across Europe, and the uncertainty that the decision to leave triggered across the continent is felt nowhere more keenly than in Ireland. The Irish National Risk Assessment on Money Laundering (ML) and Terrorist Financing (TF) makes this explicitly clear; Brexit makes up a third of the ML/TF risk-enhancing factors for the Irish state.....More

Beneficial ownership: A new era of openness? (United Arab Emirates)


Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive (4MLD), and the central registers of beneficial owners that it will introduce.

The BCCI Scandal


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

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Top 5 Money Laundering Cases of the Last 30 Years


Money laundering and, conversely, anti money laundering (AML), continues to be a hot topic, especially within businesses and large corporations, as government agencies – particularly in the US (where an estimated £231 billion is laundered annually) – continue to crack down on money laundering and sanctions violations.

Panama in the spotlight: making progress on money laundering?


There’s a saying about there being no such thing as bad publicity, though anyone who has been on the receiving end of negative media reports would probably not agree. Panama has attracted global attention as a result of the April 2016 publication by the International Consortium of Investigative Journalists of the Panama Papers.......More

All change on cash? Tackling money laundering through cash transaction limits in Germany


A good way to get an eye-catching headline these days is to carry out some research predicting the death of cash, now that we are all abandoning notes and coins in favour of smartphone apps, contactless cards and mobile payments.

All change on cash? Tackling money laundering through cash transaction limits in France


A good way to get an eye-catching headline these days is to carry out some research predicting the death of cash, now that we are all abandoning notes and coins in favour of smartphone apps, contactless cards and mobile payments.....More

Beneficial ownership: A new era of openness? (Switzerland)


Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive (4MLD), and the central registers of beneficial owners that it will introduce.

Beneficial ownership: A new era of openness? (France)


Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept set to attract much more interest over the coming months and years, thanks to the Fourth Anti-Money Laundering Directive, and the central registers of beneficial owners that it will introduce.....More

CPD – groan, do I really have to?


Come on, admit it, we’ve all thought this at some point. It’s getting towards the end of the year and your Manager or HR team are checking your records. You’re supposed to do 35 hours (or thereabouts). Some can be structured, some unstructured. Does that day spent learning how to make PowerPoints more engaging count? When was it? Oh, if only you’d written it down at the time!

Reporting Suspicions of Money Laundering and Terrorist Financing – The German Perspective


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Reporting Suspicions of Money Laundering and Terrorist Financing: Spotlight on France


We started discussing suspicious transaction reporting regimes around the world, wondering how the UK's figures compared to other countries, whether the challenges were similar and if there were similarities in the entities submitting the highest number of reports. This led to my taking a closer look at what was happening in France.

Reporting Suspicions of Money Laundering and Terrorist Financing – A Closer Look at Switzerland


At the International Compliance Association we find ourselves discussing money laundering issues almost constantly. One of the reasons that I love my job is that I get to discuss the finer points of anti money laundering regulations with other like-minded people.....More

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EBA proposed guidelines on the risk based approach and CDD risk factors


New EU Guidelines on Risk Factors and Simplified and Enhanced CDD: It’s all about the risk-based approach so get ahead with the ICA.

Infographic: Don't Look Won't Find - Transparency International Report Statistics


Billions of pounds in corrupt funds are pouring into the UK every year. Transparency International - Don't Look Won't Find Weaknesses in the supervision of the UK's anti money laundering rules.....More

OECD: tax and anti money laundering bodies need to step up joint working


Joined-up thinking is something it’s hard to argue against. But while it’s a great idea in theory, co-operation, communication and collaboration don’t always materialise on an in-house basis, let alone where different organisations are involved, even if they are pursuing similar aims.

The importance of effective and meaningful customer due diligence (CDD)


The profile of money laundering and terrorist financing risk has seen exponential growth, and the stakes have never been higher.....More

MTOs in the Pacific rising to the de-risking challenge


Remittance streams from family members living overseas form an essential source of money for many people living in the Pacific region, and a significant proportion of the GDP of many Pacific islands. However, recently these flows of money have come under threat as many global banks have ceased providing banking services for money transfer operators (MTOs) in the region, due to heightened sensitivity to AML and CFT requirements.

Compliance: in demand


It’s been said before, but for those in search of a career that is both challenging and rewarding there has never been a better time to work in compliance. The challenges come in the form of the abundance and complexity of current and forthcoming regulations, increasing scrutiny and greater enforcement activity; the rewards through the growing demand that this has created for skilled compliance professionals.....More

South Asia: Reserve Bank of India fines and anti-bribery law amendments


The Reserve Bank of India, the national banking regulator, has issued INR1.5cr (USD165,276) fines to three public sector banks and issued to cautions to eight more for failure to implement appropriate measures to prevent and detect AML/CTF. The censure comes in the wake of a thematic review of KYC in banks which found a lack of due diligence carried out in public sector banks and a concerning use of intermediaries to open and operate accounts.

Terrorism and the UK - Did you realise?


"The figures for assets frozen are remarkably low..."....More

Banks – between a rock and a hard place?


Yesterday the Financial Conduct Authority in the UK released a statement of their expectations of Banks’ management of money laundering risk:

A Call for Information, but are we asking the right questions?


In the UK Anti-Corruption Plan, published on 18 December 2014, the Government committed to carrying out a review of the suspicious activity reports (SARs) regime contained in the Proceeds of Crime Act 2002 (PoCA) and the Terrorism Act 2000 by July 2015. The purpose of which is to develop ways of better identifying money laundering and the financing of terrorism, and to prevent the movement and use of the proceeds of crime. The Home Office has, therefore, launched a ‘Call for Information’ in relation to SARs and firms are invited to respond to various questions.....More

UK AML/CFT supervision: proportionate and effective?


The HM Treasury Anti-money laundering and counter terrorist finance supervision report 2013-14, released earlier this week, aims to provide a snapshot of the progress made over the last 12 months by UK AML/CFT supervisors in:

Going Through Changes – Insight from Davos


Making sense of the threats posed to national security by transnational organised crime in the context of global responsibilities in the era of digitalisation and compliance....More

Blacklists, PEPs, corruption and regulation. How is 2015 looking so far?


January 15th saw a round of face to face meetings for jurisdictions found to be lacking in the last FATF plenary, with the APG ML in Sydney

AML and CTF: Are controls designed to mitigate risk also hampering firms?


The ‘over-zealous’ application of foreign money laundering rules means British banks are facing risks of slower growth abroad, while also meaning weaker economies are facing exclusion from global financial markets. Or at least, this was the signal sent by the BoE deputy governor, Andrew Bailey, on 4 November 2014, who said:....More

The winds of change have rolled in with the Asian Autumn


Since early October, students in Hong Kong have protested against China’s reneged promise of free and fair elections. This coming from the country who protested last when its citizens lost money en masse due to the misselling of minibonds in 2008. They used to say that HK only protests if the people lose their money. Clearly, this is no longer the case.

Calling Big Banks to aid financial inclusion and raise their social kudos


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

Stick, twist or fold? How best to manage emerging trends and best practice in money laundering and t ...


I was delighted to represent the International Compliance Association at the Compliance Officer conference in Warsaw recently which focussed on the subject of new payment technologies and emerging money laundering and terrorist financing risk management.

Changing the enforcement target: regulators, it’s time to stop just focussing on the MLRO


We have a problem. Money Laundering Reporting Officers must increasingly hit the highest standards of professionalism. This is a good thing.....More

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HSBC money laundering failures: 5 points we must all learn - for a start AML is not just a process


Up to 1 Billion USD$ in fines. Group Head of Compliance David Bagley quits. Huge reputational fallout and remedial action required. A disastrous scenario for HSBC, and a time for all working in anti money laundering to take stock. What are the lessons to be learnt.

Top Ten reasons to be an MLRO


As a small child how many of us dreamt of becoming a Money Laundering Reporting Officer? None, that’s how many. We were shallow creatures weren’t we? Chasing the tawdry allure of the astronaut, fire fighter, rock star or ballerina (or in my case for a brief ill judged period a chef).....More

New year, new law


As this is the start of the New Year, the imminent start of the Lunar New Year of the Dragon and my first offering for the ICA blog, it seems appropriate to give an overview of the AML situation here in Hong Kong and to look ahead to the new law that takes effect on 1st April 2012.

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