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Insight
2012
Offshore secrets highlight the need for transparency and strong oversight
The UK Guardian’s “Offshore secrets” series, and BBC Panorama’s concurrent investigation into the burgeoning trade in sham directorships, provided some fascinating (albeit depressing) reading/viewing for anyone interested in the prevention and detection of financial crime.....More
Cybercrime goes commercial
How some websites are using a combination of crowd sourcing, Cloud services and Internet marketing techniques to sell illegal system access and other criminal cyber services online.
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
Drugs, cycling, and the financial sector...
I’ve been keeping half an eye on the Lance Armstrong doping case that’s rocked the world of cycling and finding it hard to ignore some of the similarities it bears to the various crises and scandals that have hit the financial sector.
Money laundering – from sunbeds to cemeteries
Money launderers are an inventive lot. If they want to properly benefit from the proceeds of their crime, the necessity is to make the criminal property look legit.....More
Corporate governance: an ever expanding need for compliance to play its part
Having worked in the financial services industry for over 13 years I can see that risk, compliance and internal audit play a fundamental part in good governance. However in many organisations these functions are split, do not interact and all cite their reasons for remaining independent.
Remuneration and risk: how much has changed post-crisis?
The ongoing financial downturn in the UK has served to keep the issue of financial sector remuneration firmly in the spotlight.....More
The Adoboli trial will shine a light on controls and culture at UBS
It’s early days in the Kweku Adoboli trial, which started last week, but it looks as though the outcome (and its broader fallout on UBS and the banking sector) will hinge to a large extent on how much of a “rogue” Adoboli is.
The Tortoise and the Hare - Why speed may be less important than awareness when it comes to truly effective cyber security
A Jumbo Jet only travels fifty times faster than a horse and buggy.....More
PEPs: it’s not working, let’s face it. It's time to rethink our approach
It is time for a fundamental rethink of how regulators, lawmakers and firms manage the risk of Politically Exposed Persons (PEPs). What we are doing now is clearly not working.
How do I land my first compliance or AML role?
I have been hearing this question quite a lot in recent times, partly I think because the media is suggesting this is one of the few areas in the finance industry that is still hiring and also because those outside the finance industry see it as a way in.....More
How to restore trust in financial services
“Trust” is a current buzzword in the financial sector as the aftershocks of the LIBOR scandal and the HSBC AML case continue to be felt.
The changing regulatory environment - from the FSA to lofty 'Twin Peaks'
With the impending change in UK regulation flooding towards us like the recent wet weather, the FSA are 'drip' feeding information to the industry as they continue along their metamorphic journey in a bid to help ease the transition we will all have to deal with in some form or another.....More
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.
Will an ICA qualification get me a job?
Out of all the questions we get asked, this is one of the most frequent. And it’s hardly surprising. With the world economy still in a state of flux and unemployment at record highs in many countries, people want to know that any investment they make in their future will be worthwhile.....More
Before you jump into the Cloud...
There has been much hype about cloud computing but when it comes to breaking into the Financial Institutions (FI) here in Singapore, it seems to have hit a roadblock. Why? Well, simply because it touches something that is very crucial to an FI – data and control!
Mansion House speeches - a surprise, a little gloom and doom and some confusion
As always there were many interesting points to come out of the UK Chancellor's annual Mansion House speech this year, along with some very bad jokes. But one announcement might well have a significant impact upon the future of regulation in the UK.....More
Euro crisis, Asian woe?
It seems not to matter anymore which source of media you use for your regular burst of fun filled global news, as so much of it carriers the same sentiment; the Eurozone is in crisis. The BBC news site, from the UK, has a whole section dedicated to this topic, much like a special section on the Olympics or the US Election. The Business Times website, the online version of the Singaporean daily, has also recently seen an increase in its coverage of European news, mostly centred on Greece, Spain and Germany.
What is the difference between compliance and audit?
One question that I have often been asked during my compliance career, and that comes up quite regularly in workshops is “what exactly is the difference between compliance and audit?”....More
What is the difference between compliance and audit?
One question that I have often been asked during my compliance career, and that comes up quite regularly in workshops is “what exactly is the difference between compliance and audit?”
The A to Z of Safe Children Online (free PDF copy)
I recently delivered a presentation in Stockholm to corporate staff on the risks arising from poor social media use. During the Q&A I was asked about guidance for parents and teachers in relation to child online activities. The audience, drawn from a leading Swedish high-tech firm, told me that an estimated 50% of Swedish three-year-olds are regular Internet users with their own online identity in some shape or form. I found this statistic alarming.....More
Have you had an accident? The rise of claims management companies in the UK
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.
Compliance Allergy?
An interesting new law has just come into place in Korea which mandates that most large listed companies will have to have a compliance officer. Licensed lawyers and experienced legal academics are eligible to apply for such posts but so too are those with either a master’s degree or higher in law with at least five years of experience in audit or compliance department of a listed company or an undergraduate degree in law and ten years of experience with a listed company. Their role would be to oversee the companies’ compliance obligations and to work proactively to head off potential legal issues before they escalate.....More
Why education and training is so important for the financial services sector
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.
After the hype fades, follow through. You have been warned: bribery & corruption
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
C-R-E-D-I-B-L-E - an acronym for compliance professionals
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?
Enhanced Due Diligence – CDD on Steroids?
But could it generate career opportunities in compliance roles in Jersey? Or, as John Harris, Director General of the Jersey Financial Services Commission (JFSC) quoted in his speech at the November 2011 Jersey Economic and Financial Crime Symposium:“Client Due Diligence (CDD) Plus Plus”....More
Digital Criminal 2012: CyberSafety Report
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.
Rules were made to be broken...
‘These rules don’t make sense’ ‘I don’t understand why we need these rules’ ‘We never used to have so many rules we had to follow’ ‘Do we really have to follow these?’ Sound familiar? I thought they might.....More
Preparations for the UK Financial Conduct Authority are gathering pace
With recent speeches to the British Bankers' Association by both Martin Wheatley and Clive Adamson, and the resignation of Margaret Cole, we are beginning to get a clearer picture of the approach and focus of that the Financial Conduct Authority will have when it assumes its powers in a year's time.
New Law – new guidance (Hong Kong)
Following on from my first blog describing the new Anti-Money Laundering Ordinance (AMLO) in Hong Kong that takes effect on 1st April 2012, the Hong Kong Monetary Authority (HKMA) which regulates banks in Hong Kong published its revised “Guideline on Anti-Money Laundering and Counter-Terrorist Financing” on 27th January.....More
PPI. High profile letters, big losses. Could this be the most undesirable three letter combo?
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?
Corruption: the perception and the reality
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.....More
Don't they say that life begins at 40? FATF believe so.
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.
A compliance practitioner's work is never done...
When a compliance professional receives that notification in their inbox from either the FSA, OFT, ICO or other regulatory/oversight body; what do they do?....More
Inside Job - Storyville
Sitting in the Planner from the tail end of 2011 was ‘Inside Job – Storyville’. The synopsis said it was an Academy Award winning forensic analysis of the 2008 global financial crisis, tracing the emergence of a rogue culture within the finance industry which has corrupted politics, regulation, and academia. At a cost over $20 trillion, the crisis caused millions of people to lose their jobs and homes in the worst recession since the Great Depression, and nearly caused global financial collapse. And Matt Damon does the voiceover.
Madoff the movie - a story that you couldn't make up
This year Hollywood star Robert De Niro is set to star as disgraced financier Bernard Madoff, in an HBO movie which he will also produce. The case of Bernard Madoff’s Ponzi scheme is pretty stunning and is referenced in ICA's Financial Crime Prevention Diploma material. As far as I know, Mr De Niro has not taken the ICA Diploma (as yet, but his application is most welcome).....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.
“Smell Test” You will know it when you see it
“The Puppet Masters” report issued by the World Bank in November, while lengthy, is a quality source of information and guidance on the ever thorny issue of beneficial ownership. It does take a few minutes to fully load – be patient, it’s worth the wait.....More
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