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Insight
2015
Cyber security, an ongoing concern for 2016
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
International Anti-Corruption Day – What can we do?
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.
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
US SAR stats turns spotlight on crowdfunding
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.
Education underpins accountability
The drive for responsibility and accountability continues to gather pace. Christine Lagarde, Managing Director of the International Monetary Fund, has placed the global spotlight firmly on the role of the individual in a 5 November speech to the New York Fed.....More
Single Criminality vs Dual Criminality
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?
TalkTalk hack raises important questions about regulation and data protection
The details that have emerged since the 21 October cyber attack on TalkTalk raise some serious questions not only for the broadband provider itself but for any business holding sensitive customer information.....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.
Market failure and bad behaviour: where does the individual sit in all of this?
People tend to assume a different persona within the workplace, in much the same way as many individuals adopt a completely different set of social standards when they get behind the wheel of a car.....More
Threat of “KYCC” highlights need for joined-up approach to financial inclusion and financial integri ...
“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.
The 4th EU Money Laundering Directive explained in 90 seconds
The Directive was finally adopted on 20 May 2015. It reflects the 40 recommendations that were published by FATF in 2012 and these repeal the 3RD EU Directive.....More
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.
The FIFA Story, Part 2 – Now the dust has settled
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.....More
Compliance Spain: new training needs
Transparency International’s Global Graft Report reports that "corruption is everywhere in Spain". Their latest Corruption Perception Index has Spain sitting in lowly 37th spot. The Q4 political scandal season didn't even make the print deadline for the 2014 GGR. For example, the Health Minister was sacked in November 2014 after being named as a “profit-seeking participant” in connection with the Gürtel corruption case.
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.....More
FCA Annual Report: Part 2
As we know the FCA strategic objective is to make markets work well, and to achieve this they have the operational objectives of: - Protecting consumers - Protecting and enhancing the integrity of the financial systems - Promoting competition in the interests of consumers.
FCA Annual Report July 2015
The FCA has issued a comprehensive review on its progress over the year including how it has achieved its objectives. This is a quick overview of how it assesses its performance in discharging its powers as a regulator. In ICT, we explain to our delegates that the regulator has four main powers:....More
Digitisation, Trust and Regulation
I attended the BBA conference last week in London, it was a pretty long day but well worth the effort. There’s some exciting changes facing the banking sector over the next few years and many of these were discussed at the event. The three areas highlighted as being the key challenges for the sector include:
Standards and individual accountability in FICC markets
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
Mansion House – implications for Compliance?
Our financial services industry in Britain has, in recent years, been seen as part of the problem – now it must become part of the solution. That was the message from George Osborn MP, Chancellor of the Exchequer, in his 2015 Mansion House speech.
The FIFA Story, Part 1
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!....More
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.
“The Beautiful thing about learning is nobody can take it away from you.”
Can you guess where this quote is from? The quote in itself is beautiful, don’t you think? It is not from Einstein, or Socrates, or even Gandhi who all have attributed to them great sayings about learning and wisdom. This quote is actually from B.B. King American blues singer and musician, who sadly died last week. For me, this quote encapsulates everything about why people engage in a journey of learning, it is more to do about something within you rather than something outside of your control. Because the reality of it is that once you embark on a course of study, for example a degree, or a postgraduate course or diploma of some sort, only you can determine the success of achieving that goal.....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:
Lobbying: fostering a culture of integrity
There is a serious shortfall in transparency, integrity and equality of access within the lobbying process across Europe, according to a report released last week by Transparency International. This has created a need to “foster a culture of integrity among companies and organisations seeking to influence public policy,” says TI.....More
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.
When enforcing the tone from the top really appears to mean low hanging fruit
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.....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:
How much do APAC's regulators earn?
Regulators’ salaries across Asia Pacific vary enormously:some supervisors earn fortunes and others hit the pay scale at the average to low end.....More
Switzerland to return $380 million to Nigeria in Abacha case
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).
Continuing the drive towards professional standards
The call for greater standards of professionalism within the financial sector has increased in volume in the years following the financial crisis. And no doubt that call will continue to get louder.....More
Compliance in Russia
On 26 February I had the privilege of representing the ICA by attending and speaking at the 4th Annual ICA Conference in Moscow, organised by our Russian partners, International Compliance Services. This year the conference theme was ‘The Era of GRC: Governance, Risk and Compliance – Introducing the Unitary International Compliance Standard’.
RBS - What the annual results tell us
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
5 ways to maximise your workshop experience
For those of you who are based in a country where we offer workshops as part of your course, here are a few hints and tips on how you can maximise your workshop experience.
HSBC & Financial Crime: What the Annual Report tells us
It seems HSBC are never out of the headlines at the moment, and the detail becomes more incredible each time (allegedly the Chief Executive’s bonuses were paid to an anonymous Panamanian holding company and then kept in a Swiss bank account).....More
Getting regulation right: a universal challenge
Financial regulation has received so much mainstream attention in the recent past that it’s easy to forget that criticisms of “toothless regulators” or of the “glacial pace of regulatory change” are universal, and that the need for improved regulation and compliance expertise cuts across many sectors of the economy. The most recent example comes from the world of groceries retailing.
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
Europe: cash banned from 2020
A leaked memo* has revealed that in five years’ time, all personal and commercial transactions in the broader EuroZone will have to be undertaken electronically, using facial recognition identification technology.
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....More
Trade-based laundering – is automation the key?
Automated systems are great, but it still comes down to people to understand the information and make the appropriate decisions so, as an institution’s first line of defence and arguably its greatest asset, this is where we should be seeing significant investment.
Digital Banking
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:-....More
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