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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.
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
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.
$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.....More
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.
Money laundering scandals have been all over the news recently, with banks such as Danske and Swedbank....More
On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbrokers
Great strides forward have been made in the general awareness....More
Compliance culture, especially in financial services, is a really important element that can impact on the wider cultural challenges that a firm could face.
When correctly motivated, employees remain honest and become the most effective frontline defence against the fraudster. Employees become motivated when they believe that:....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.
I’ve worked in financial services for 30 years across a range of roles in front office and support functions, leading sizeable teams with multiple jurisdiction responsibilities. I joined the ICA two years ago as a Fellow after graduating with a Post Graduate Diploma in Governance, Risk & Compliance. I’m also a member of the ICA Technical Advisory Board.
I’ve worked in financial services for 30 years across a range of roles in front office and support functions, leading sizeable teams with multiple jurisdiction responsibilities. I joined the ICA two years ago as a Fellow after graduating with a Post Graduate Diploma in Governance, Risk & Compliance. I’m also a member of the ICA Technical Advisory Board.....More
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?....More
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?
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
We examine the case of automotive giant Volkswagen, the most recent household name to be hit by US authorities for breaching laws and regulations.
Odebrecht and Braskem, two Brazilian companies, have been fined at least US$3.5 billion after pleading guilty to bribing government officials.....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.
How equal are women? According to the World Economic Forum (WEF), not very. It released the startling estimate that we will have to wait until 2095 to close the gender gap. The UN has pledged to tackle this and want to achieve gender equality by 2030.....More
The Telegraph wrote an article this week entitled “Banks ordered to treat vulnerable customers with empathy”, which looked at a problem that exists in banking where vulnerable customers are still being treated poorly.
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.....More
2015 proved a busy year for corruption scandals in sport, arrests and resignations of FIFA officials and allegations of cover ups of doping in athletics have shocked many. So maybe 2016 will offer some respite to weary folks? Not so far.
“Implementation Day” – the lifting of sanctions following Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) – came around more swiftly than some had anticipated at the time that the JCPOA was initially agreed. Anyone not expecting compliance to be achieved so rapidly will be feeling the pressure to get fully up to speed with this new landscape.....More
If you work in regulated financial services in the UK, you will have heard about the UK Senior Managers & Certification Regime by now. There’s quite a lot to it, so ICA have summed up some of the key information in some FAQs.
With the rising cost of data breaches and the rising volume of attacks, cyber security was one of the highest profile issues facing businesses in 2015. Cyber attacks are currently believed to cost business anywhere between $400-500bn a year and show little sign of abating.....More
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.
“There is a risk of setting a ‘know your customer’s customer’ standard for the whole global system,” Anders Borg, former Swedish Finance Minister, has warned.....More
It is with some disquiet and unease that I have been reflecting on the finer points of the recent enforcement action that was published earlier this month by the FCA concerning the affairs of the Bank of Beirut and in particular the personal sanction announced of the Compliance Officer and Internal Auditor, and I felt compelled to put pen to paper.
As a neat follow up to Dave Robson’s blog earlier this week (view here), which provided a succinct analysis on two key areas of the HSBC annual report, risk and legal proceedings, here’s my take on the RBS 2014 results released yesterday. Bearing in mind you and I (the UK taxpayer) own almost four-fifths of RBS; it’s an opportune time to find out how they are performing, particularly around risk.....More
As we enter 2015 financial institutions are confronted with an uncertain and shifting economic and political landscape. 2014 has seen slower than hoped for global economic expansion with stalling Chinese growth and the burgeoning Rouble crisis, while the current situation in Greece places the future of the Eurozone in the balance. Meanwhile, for UK financial institutions, political uncertainty abounds ahead of the next general election.
The OECD Foreign Bribery Report, released earlier this month, provides some interesting insights into corruption within international business. Not surprisingly, it highlights the usual sectors as hotspots for bribery and corruption activity. Drawing on data from the 427 foreign bribery cases that have been concluded since 1999 (when the OECD Anti-Bribery Convention first entered into force) the report finds that the extractive sector accounted for 19% of these, construction 15%, and transportation and storage a further 15%.....More
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:
The Office of the Comptroller of the Currency (OCC), the primary regulatory agency for national banks and Federal savings associations in the US, has provided final guidance on higher standards for risk management in larger banks.....More
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.
We have all been on the receiving end of claims management companies (CMCs) offering to help you claim for an accident at work or car accident which wasn’t your fault. In fact if you watch daytime TV or listen to local radio, you will find that every second advert is one of those firms, usually endorsed by a well known celebrity to promote confidence in their services.....More
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.
As compliance professionals we all strive to save our businesses from the expense and reputational damage that comes with regulatory censure, but how do we get our businesses to understand and buy in to the value that we add to their bottom line?....More
So it has arrived – the revised version of the FATF 40 + 9 and what do we see? I am sure I will not be the only blog or commentary on this issue, and I definitely need to take a more in depth look, but I thought I would share my very initial observations and thoughts.