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Insight

2016

Financial regulation in the US: an uncertain future?


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

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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?

No Double Dutch in sight! Corporate Governance and Anti-Bribery Standards in the Netherlands


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.....More

Gibraltar and Brexit – Rock and a Hard Place?


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?

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.....More

Greece: Could effective GRC have prevented the economic crisis?


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.

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

Technology: the future of tackling insurance fraud in Ireland?


The insurance market is a dynamic sector offering increasingly sophisticated products to its customers and providing competition to other parts of the financial services industry. The insurance sector’s growth is particularly noticeable with some jurisdictions reporting a doubling of premiums in the last decade.

Sweden: A World Leader for Transparency


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.....More

Do you really know your customer?


Do you know your customer? Do you? Really? If someone asked you to “sum up the financial crime risks posed by the relationship”, would you be able to do it?

Our top seven Switzerland blogs on money laundering, terrorist financing and beneficial ownership


A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.....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.

My top 10 quotes on learning


“Tell me and I forget, teach me and I may remember, involve me and I learn.” ― Benjamin Franklin. At ICT, we are passionate about learning and development and tens of thousands of individuals and firms all over the world have realised their training ambitions through us.....More

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Fraud in Switzerland - an update on high profile fraud related stories


We don’t know who originally had the idea for committing financial crime, although what is said to be the first recorded incident of fraud – involving a Greek merchant called Hegestratos, an upfront payment for transporting a cargo of corn and a failed plan to scuttle the ship carrying it – dates back to around 300 BC.

Fraud in Germany: the financial crime that needs a 21st century fraud response plan


We don’t know who originally had the idea for committing financial crime, although what is said to be the first recorded incident of fraud – involving a Greek merchant called Hegestratos, an upfront payment for transporting a cargo of corn and a failed plan to scuttle the ship carrying it – dates back to around 300 BC.....More

Fraud in the Netherlands: the financial crime that needs a 21st century fraud response plan


We don’t know who originally had the idea for committing financial crime, although what is said to be the first recorded incident of fraud – involving a Greek merchant called Hegestratos, an upfront payment for transporting a cargo of corn and a failed plan to scuttle the ship carrying it – dates back to around 300 BC.

Fraud in France: the financial crime that needs a 21st century fraud response plan


We don’t know who originally had the idea for committing financial crime, although what is said to be the first recorded incident of fraud – involving a Greek merchant called Hegestratos, an upfront payment for transporting a cargo of corn and a failed plan to scuttle the ship carrying it – dates back to around 300 BC.....More

Germany: Trusting Third Parties


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.

Germany: Trusting Third Parties


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

Warning to banks in Hong Kong


The Monetary Authority of Singapore launched a dedicated anti money laundering (AML) department on 1 August, and this triggered my interest in reading more about AML-related developments in Asia Pacific. I came across an article from May this year which talked about how regulators in Hong Kong, for example the Hong Kong Monetary Authority (HKMA), are cracking down on trade based money laundering (TBML).

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

Corruption: perception and reality in Ireland


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.

Infographic: ICA Open Day - 13 September 2016


Still wondering whether to come to the ICA Open Day (or one of the local sessions)? Then have a look at our infographic for a few compelling reasons to register your place this year.......More

Switzerland: Tone from the Top of the Alps


A high percentage of Switzerland's surface is covered by the Alps. The melting of glaciers, located at the top of the mountains, generates flows of clean – and essential - water for a wide range of ecosystems downstream. This natural geological phenomenon helps us to illustrate the importance of the commitment from the Board of Directors and Senior Management to implement compliance across all hierarchical levels in Swiss companies.

The FCA Anti-money laundering annual report 2015/16: progress – and challenges


The UK’s Financial Conduct Authority (FCA) has published a small library of reports this month, including its Anti-money laundering annual report 2015/16, which provides some interesting insights into its work, and some themes emerging from this, over the last year.....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.

The FCA Annual Report: taking a closer look


Here in the UK, after weeks of blanket media coverage around Brexit, a change of Prime Minister and the legal complexities involved in the Labour leadership election, we could be forgiven for wanting a change of subject matter. So the Financial Conduct Authority’s (FCA) Annual Report for 2015/16 could provide a welcome respite for financial services professionals, though it’s not exactly what you might call light reading.....More

Football, mobile phones and money laundering


Bright ideas are the lifeblood of any business or organisation. The same applies to money launderers, who always seem to be coming up with new techniques of their own, or abusing entirely legitimate systems and technologies, in order to stay a step ahead of law enforcement and other authorities.

Corruption: perception and reality in the Netherlands


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.....More

Life after the referendum: terrorist financing high on FATF agenda


Here in the UK, there’s not much on our news agenda apart from the EU referendum outcome and the resulting fall-out, so significant developments elsewhere in the world since 23 June have perhaps been slipping under our radar.

Focus on France: Football, Tennis, Cycling, Corruption…?


It’s all focus on France at the moment. A few weeks ago it was widespread strike action which was grabbing the world headlines as protests against reform of the French labour code caused significant disruption across the country. And now, with the 2016 European Football Championships progressing towards its conclusion, the Tour de France will be hot on its heels showcasing the beauty and variety of the French way of life.....More

Pleins phares sur la France : Football, Tennis, Cyclisme… et Corruption ?


Tous les yeux sont tournés vers la France ces derniers temps. Il y a de cela quelques semaines, les grèves générales suite à la proposition de réforme de la Loi Travail ont perturbé le pays et fait les gros titres. Aujourd’hui, la fin de l’Euro de football approche et c’est le Tour de France qui prendra bientôt le relai et exposera la « manière de vivre à la française » aux yeux de tous.

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

Reporting Suspicions of Money Laundering and Terrorist Financing: Spotlight on the Netherlands


At the International Compliance Association, we regularly find ourselves discussing money laundering and related issues. The reporting of suspicious transactions is a topic that often crops up and we’ve recently done some work around different reporting regimes around the world, how figures from different countries compare, whether national challenges are similar and if there are similarities in the entities submitting the highest number of reports. As a result, I took a closer look at the Netherlands.

Tone from the top: back in the spotlight


Ethics is high on corporate agendas these days. The financial crisis of almost a decade ago has had far-reaching implications, not least in encouraging the leaders of companies in all sectors to take a long, hard look at how their organisations do business and whether they are doing it in the right way.....More

Anti-Corruption Conference raises corruption awareness and there’s no room for complacency


The UK-led Anti-Corruption Summit held in London earlier this month attracted some significant publicity, much of which focused on David Cameron’s inadvertent remark that Nigeria and Afghanistan were ‘fantastically corrupt’.

Beneficial ownership: A new era of openness? (The Netherlands)


Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept that seems guaranteed to attract a great deal of international interest over the coming months and years, not least because of the European Union’s Fourth Anti-Money Laundering Directive (4th AMLD) and the central registers of beneficial owners that it will introduce.....More

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


Beneficial ownership is a phrase likely to leave the average person baffled and probably not very bothered. But it’s a concept that seems guaranteed to attract a great deal of international interest over the coming months and years, not least because of the European Union’s Fourth Anti-Money Laundering Directive (4th AMLD) and the central registers of beneficial owners that it will introduce.

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


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

Comentario sobre la Circular de la Fiscalia General del Estado 1/2016


No habiendo todavía jurisprudencia consolidada sobre la cuestión de la responsabilidad de personas jurídicas, la circular 1/2016 de la Fiscalía General del Estado, a pesar de no tener carácter imperativo puesto que los fiscales ejercerán sus evaluaciones caso por caso, representa un hito en cuanto concierne a la interpretación del marco normativo.

5 Top Tips for writing your ICA assignment


5 Top Tips for writing your ICA assignment....More

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Interpreting ICA Assignment Feedback


Ping. Here’s the email – the mark for your ICA Advanced Certificate or Diploma assignment is now available. Gulp. Time to access the ICA website. Let’s look at the two main scenarios that tend to unfold...

Panama Papers: Offshore Leaks Database


The international Consortium of Investigative Journalists has now released an Offshore Leaks Database, further lifting the secrecy from thousands of offshore entities from its Panama Papers investigation and its 2013 Offshore Leaks expose. Here's some of what it reveals.......More

Leicester City FC – A benchmark of good culture?


I, along with almost everyone in the country (save, perhaps, for a small section of North London), have probably been celebrating Leicester City’s Premier League success alongside the good people of Leicester. It’s one of those events that come around every now and again, which allows us all to jump on board the ‘feel-good express.’

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


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

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

Culture still a priority for FCA despite abandoned review


The year began with the FCA coming under heavy criticism for suspending its thematic review into banking culture. However, the regulator recently reaffirmed in its Business Plan for 2016/17 that firms’ culture and governance is one of the seven priority themes around which it will organize core activities for the coming year.

From the Panama Papers to people with significant control


​The Panama Papers have truly put the cat among the global pigeons. What the rich, powerful and famous from around the world have been secretly getting up to offshore makes fascinating reading and the revelations have already toppled one prime minister.....More

Compliance: votes from the Spanish jury


Enforcement remains one of the unknown quantities following Spain's long-awaited Compliance reform in mid-2015.

Cumplimiento: los votos del jurado español


Tras la esperada reforma sobre cumplimiento en España de mediados de 2015, su aplicación sigue siendo una de las grandes incógnitas.....More

Corruption: is perception reality? (France)


‘All power tends to corrupt, and absolute power corrupts absolutely.’ – Lord Acton

Corruption – is perception reality? (Germany)


“All power tends to corrupt, and absolute power corrupts absolutely” – Lord Acton.....More

Corruption – is perception reality? (Switzerland)


‘All power tends to corrupt, and absolute power corrupts absolutely.’ – Lord Acton

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


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

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!

Transforming whistleblowing culture for the long term remains a challenge


Since the Financial Conduct Authority (FCA) replaced the Financial Services Authority there has been a short run, but dramatic, trend in the UK towards greater whistleblowing activity. 2014 saw 1,367 complaints reported to the FCA, an increase of 44% on 2013 and of 142% on 2012. However, in 2015 reported complaints declined by a fifth compared with 2014, according to law firm Pinsent Masons.....More

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


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.....More

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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.

International Women’s Day 2016: What’s it got to do with governance, risk and compliance?


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

Vulnerable Customers and Conduct Risk


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.

The Senior Managers Regime - what are your priorities?


Several months ago we carried an article in our magazine InCompliance about the new Senior Manager and Certification Regime....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.

Financial crime: Views on the news


LIBOR, conspiracy to defraud, the Bank of England, Barclays, Qatar, dual criminality and some other observations…….....More

Corruption in Sport – Lessons Learnt


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 presents a shifting sanctions landscape


“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

Frequently asked questions about the UK Senior Managers & Certification Regime


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.

Infographic: ICA Open Day - 3 February 2016


Still wondering whether to come to the ICA Open Day (or one of the roadshows)? Then have a look at our infographic for a few compelling reasons to register your place this year....More

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