Written by James Thomas on Monday 3 October, 2022
Collaboration is increasingly viewed as an essential tool in the global fight against financial crime.
With criminals showing growing ambition and sophistication – often aided by developments in technology or the increasing complexity of the financial system itself – the challenge confronting anti-financial crime (AFC) professionals is significant. However, through cooperation between the private sector, law enforcement and regulators, and the pooling of resources, knowhow, data and analytics capabilities, clear opportunities to scale up the efficiency and effectiveness of AFC efforts are emerging.
From a practitioner perspective, such initiatives offer considerable scope to advance best practice and knowledge across the compliance profession.
Stronger together
Public-private partnerships (PPP) are far from straightforward, often being hindered by data sharing issues or broader technological, commercial or logistical factors. The Fintel Alliance – a successful PPP involving AUSTRAC (the Australian AML/CFT regulator and financial intelligence unit), Western Australia Police and analysts from Westpac, NAB, CBA and ANZ – provides a standout example of how such challenges can be addressed in practice, and the positive outcomes which can accrue.
The partnership won Best Collaboration of the Year at the 2022 ICA Awards for its work in identifying and disrupting organised crime syndicates which were using ATMs to launder the proceeds of crime. ANZ’s Financial Crime team created an algorithm to centre on the ATM, effectively regarding the deposit machine as the ‘customer’ and enabling them to observe instances in which a terminal had been used intensively over a period of time, with a long chain of transactions made on behalf of several different customer accounts. Although historically financial institutions investigate anomalous activity at the account or customer level, this algorithm was able to ‘connect the dots’ and determine the sum deposit value from the overall activity, with other intelligence holdings, such as CCTV, providing more details about the depositing party.
Positive outcomes
The bank presented its findings to the Fintel Alliance and disseminated the business rules for the creation of ‘clusters’ of potential interest. The participating banking members of the Fintel Alliance then held a ‘week of action’ to share close to real-time bank data, which identified targets for investigation. This intelligence was disseminated to Western Australia Police, supporting a live law enforcement investigation, codenamed ‘Operation Saintly’, which resulted in the seizure of AUS$770,000 in cash, as well as vehicles, firearms and ammunition, encrypted communication devices, and commercial quantities of cocaine, MDMA, methamphetamine and cannabis.
Following the success of the operation, the Fintel Alliance supported law enforcement in the investigation of ‘Operation Taipan’, focused on one of the largest money laundering syndicates in Australian history, which police allege laundered around AUS$62 million in cash. Again, the positive outcomes were significant, including the seizure of AUS$2 million in cash, four luxury cars, jewellery and illicit tobacco. To date, the partnership has led to 13 arrests.
Sharing best practice
At this year’s ICA Leading Financial Crime Compliance APAC Summit, Milan Gigovic, Head of Financial Crime Threat Management, ANZ, will share his experience of the workings of the Fintel Alliance, offering insights into how AFC professionals can maximise the value of such partnerships. If you are interested in learning more, visit: https://ica-apacsummit.int-comp.org/
A chance to win
The ICA Compliance Awards Europe 2023 is back for another year to celebrate the outstanding achievements of teams and individuals, recognising innovation and collaboration across the compliance community. Share your success stories with the ICA team and a panel of expert judges, to receive an independent stamp of approval and to validate best practice.
This year we’ve revised the 18 categories to provide opportunities to recognise the achievements of all stakeholders working across the compliance ecosystem. You’ll find categories for internal compliance teams – across all industry sectors – as well as compliance advisory, law firms and RegTech providers, who all play a critical role in delivering compliance excellence.
Entry deadline - 25 November 2022
Download Entry Guide – https://icacomplianceawards.int-comp.org/entry-guide
View Categories – https://icacomplianceawards.int-comp.org/categories
Start Your Entry Now - https://icacomplianceawards.int-comp.org/