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Insight
AML
Inflation: A breeding ground for financial crime
Inflation has ripple effects on individuals and businesses, posing a wide variety of threats to the economy. It not only affects a country’s financial stability, but also results in increased financial crime rates.....More
I’ll do it tomorrow: Procrastination and the art of putting things off
Putting things off can cause delay, discomfort and missed deadlines. Here’s how to avoid the pitfalls of procrastination.
The Future of AML
ICA’s latest report provides a range of perspectives on the challenges and opportunities within anti money laundering....More
How to prevent AML failures
Analysing past AML failures can help firms shore up their own money laundering controls, writes Jake Plenderleith
How effective beneficial ownership searches leverage technology
Where is the sweet spot on understanding the UBO of the entities your firm does business with?
Focus on professional enablers puts lawyers in spotlight
Increasing global regulation is putting the legal sector’s relationship with money laundering under the spotlight....More
FCA warns challenger banks in thematic review
In April 2022, the UK’s FCA published a thematic review, highlighting a range of financial crime issues that required remediation.
Fraud risks grow as cost-of-living soars
The cost of living has rocketed – which means firms must prepare for a rise in fraud....More
3 major talking points from 2021 for the compliance industry
With 2021 quickly drawing to a close, now seems an apposite time to reflect on the last 12 months
SARs reporting in the service sector
Why is the number of SARs being raised in the service sector so low when compared to credit institutions, like banks?....More
Why I loved being an MLRO
Being an MLRO can be tough, but it is also exciting and fulfilling with many opportunities for personal and professional development
Effective AML training: four questions to answer
Ensuring your employees are adequately trained in anti money laundering (AML) is a crucial component of managing financial crime risk. Not only is it vital to protect your firm, but its often required by regulations.....More
[Video] All you need to know about 6AMLD
In this video, James Wood-Rickett, Course Director, Global Lead - Anti Money Laundering, ICA, considers the key changes of 6AMLD.
Working together to stop money laundering
FATF President, Dr Marcus Pleyer, shared a vision for the future of AML at ICA’s BIG Compliance Festival....More
Top 10 reasons to be an MLRO
As a small child, how many of us dreamt of becoming a money laundering reporting officer? None, that’s how many. So, what makes the role of the MLRO today an attractive one? Here are the top ten reasons to take up the life of an MLRO.
Which ICA qualification is right for me?
This is the question we get asked the most. Although you can find out more by signing up to one of our free online Briefing Sessions, the guidance below will help to get you started.....More
The future of AML frameworks – PPPs to the rescue?
Are current anti money laundering (AML) efforts sufficient to fight the evolving financial crime threat? Are they effective? What improvements can be made to AML frameworks? This is the first in a series of articles in which we will be asking profound questions of current AML practice, and presenting the case for a major rethink of AML regimes.
BIGCompFest2020 | Part one highlights
ICA's BIG Compliance Festival 2020, the BIGGEST online event for regulatory and financial crime compliance professionals in 2020.....More
Commerzbank’s FCA fine demonstrates danger of AML lapses
A comment on the fine imposed by the FCA on Commerzbank, and a discussion of the wider implications.
The changing world of anti money laundering
Current thinking around anti money laundering (AML) is flawed and is in desperate need of a rethink. The fundamental nature of money laundering, and how we combat it, needs examining.....More
Shining a light upon our AML failings
The answer to being more effective at stopping money launderers is to challenge the value of processes that are clearly failing. Financial crime expert Martin Woods explains.
[Infographic] The Big Compliance Festival 2020 highlights (Day one and two)
Key highlights and quotes from the Big Compliance Festival 2020, the BIGGEST online event for regulatory and financial crime compliance professionals this year.....More
3 weaknesses that led to Malaysia’s 1MDB scandal
1MDB, the financial scandal linked to prominent figures in Malaysia, is under investigation in a number of countries, and those alleged to have committed crimes are slowly being brought to justice.
After 1MDB, Malaysia steps up its AML/CFT efforts
The cost of financial crime to the global economy is estimated at $1.45 trillion, according to Thompson Reuters report. Eye-watering even as an estimate, the figures are, however, no less alarming when broken down. In the Asia-Pacific region for example, financial crime is thought to cost local economies a combined $166 billion (unsurprising, perhaps, to those who have been following the 1MDB trial).....More
CDD challenges all in compliance will recognise
Individuals working in compliance may know what they are required to do in respect of CDD – and know how to do it – but may be unsure or confused as to why. Here are four questions that those working in compliance and conducting CDD might be asking themselves on a regular basis.
Future proofing the compliance professional
Technology is set to have an impact on the way in which compliance professionals work. In a future defined by VUCA, what can compliance professionals do to ensure that they have the skills to prepare for the changes?....More
United Arab Emirates: the rapid pace of regulatory change
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.
Financial crime: a 360-degree view (Podcast)
Broadgate Search sat down with Pekka Dare, Director of Training Education and Development at ICA, to uncover various case studies in the financial sector.....More
Virtual Currencies – four key updates in 2019
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.
How new technologies help prevent money laundering
$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
Correspondent banking – why it's important to understand the risks
Money laundering scandals have been all over the news recently, with banks such as Danske and Swedbank
Irish stockbroker enforcement action: What were the issues and why do they matter?
On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbrokers....More
Why collaboration is vital to combat money laundering
Great strides forward have been made in the general awareness
Monetary Authority of Singapore launches debut enforcement report
The Monetary Authority of Singapore details enforcement actions and key initiatives as it launches debut enforcement report.....More
Standard Chartered $1.1 billion enforcement action: what lessons can we learn?
It was announced that Standard Chartered has agreed to pay more than $1 billion to US regulators and the UK’s Financial Conduct Authority (FCA). What lessons can we learn from this?
The UK’s anti money laundering regime – A time for celebration?
Mutual evaluations from the Financial Action Task Force (FATF) are big news within the anti money laundering (AML) community; its peer reviews provide insight into the AML framework of a country, the key risks that it faces and how those risks are managed.....More
Skills and Attributes of an AML Professional - Infographic
Have you ever wondered which skills and attributes are useful when working in anti money laundering (AML)? If you currently work in AML, have you considered how your own skills measure up? Here’s a quick look at some of the skills and attributes that an AML professional may need
[Infographic] FATF Reports in Brief: Human Trafficking Infographic
In August this year, the Financial Action Task Force (FATF) published a new report that aims to raise awareness and provide an updated and more precise understanding of the financial flows related to human trafficking.
A look at the illicit financial flows from wildlife crime and illegal wildlife trade
When asked to consider IWT, many people would think of ivory and tiger skins; but it is so much more than that. IWT can be broadly defined as ‘any action which contravenes current legislation (nationally or internationally) governing the protection of animals and plants’ (NPCC).....More
More focus required on professional money launderers
The Financial Action Task Force (FATF) has recently produced a report looking at the ways in which individuals and organisations, known as professional money launderers (PMLs), are charging fees or commission for providing a money laundering service to criminals.....More
Pakistan added to FATF Grey List
The FATF’s International Cooperation Review Group (ICRG) identified four key areas of concern in respect of Pakistan; can these be resolved?
Given ample opportunities, Canara’s inadequate action led to FCA fine
The £896,100 fine recently imposed on Canara Bank by the FCA is a useful example of the thinking behind penalties issued by the UK regulator.....More
With a FATF visit looming, Hong Kong steps up AML/CFT efforts
FATF’s mutual evaluation in Hong Kong later this year will be its first evaluation in the territory since 2007.
EU fifth anti money laundering directive (5MLD)
Here’s an insight into some of the changes put forward in this fifth and latest update.....More
How high risk is trade finance?
What is trade finance and is it really as high-risk as it is often perceived?
Are we becoming a cashless society?
Biometric technology, contactless cards and online shopping. Is this the beginning of the end for cash?....More
Why is it important to know your customer?
Do you ever truly know your customer? And, if you don't does it really matter?
The rise of the unregulated online gambling industry
Should the anti-money laundering (AML) community be concerned at the prevalence of such Bitcoin services, and their open lack of regard to customer due diligence (CDD) controls?....More
The importance of tone from the top and why it should not be underestimated
As firms continue to navigate the labyrinthine minefield of legislation and regulation and claw their way up the evolutionary ladder of compliance with standards that appear to have moving goal posts, ‘tone from the top’ has never been more important.
Everything you need to know about mobile financial services
Over the last decade, mobile financial services (MFS) have been instrumental in increasing financial inclusion in developing markets. What impact does this have on financial services and the telecommunications industry?....More
Why policy makers should shoulder responsibility for UK failings
In November 2017, Transparency International (TI) published the report Hiding in Plain Sight which further highlighted the attractiveness of UK Plc to those that wish to launder the proceeds of corruption or value of other criminal origin.
Blurring the lines: how technology is shaping illicit finance typologies
As technological innovation sweeps the financial sector, the compliance professional faces developments of huge consequence.....More
Top five blogs on anti money laundering of 2017
As the year draws to a close, it’s always a good opportunity to reflect on the past 12 months. With this in mind, I took a look back at the blogs International Compliance Training has published on anti money laundering in 2017 and chose my five favourites.
A turning tide? Terrorism and the Caribbean
How many of us, if we were then asked to think of terrorism and the Caribbean, would think back to the bygone era of piracy; of Calico Jack and mutiny on the seas? This era ended around the 1830s so surely terrorism is something that now happens outside of the Caribbean, doesn’t it?....More
Meet an ICA Member with Jerry Walters
Jerry Walters has a Distinction in the International Compliance Association Diploma Course in Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF). As well as being a member of the ICA, Jerry is a former Detective Constable and has worked on high profile cases including Operation Trilby. He is still involved in all aspects of tackling financial crime through the running of his own business. Here, Jerry discusses what ICA and compliance means to him.
Money Laundering and North Korea
I read an article recently that highlighted how North Korea is using Hong Kong to launder their criminal proceeds. The article described the use of shell companies established in the region that provide the Democratic People’s Republic of Korea (the official name of North Korea) with access to the global financial system. Severe international sanctions are in place to restrict this access to North Korea, so any advantage they can gain is really important for them to maintain the best access they can.....More
A closer look at Denmark’s anti money laundering efforts
Denmark sits at the enviable position as the ‘cleanest’ country in Transparency International’s Corruption Perception Index (CPI). As previously discussed in ICA Insights, although deemed to be the cleanest, Denmark isn’t free from all financial crime woes.
Combattre le blanchiment d'argent par la limitation des paiements en liquide
Avec Tracfin et certaines lois récemment instaurées, la France est un acteur européen majeur dans la lutte contre le blanchiment d’argent et le financement du terrorisme. Quels ont été les changements effectués lors de ces dernières années ?....More
Anti money laundering: a spotlight on Sweden
At the International Compliance Association, we regularly find ourselves deliberating money laundering issues, which can range from recent enforcement actions to newly published reports showing the latest figures for details such as suspicious activity reports or jurisdictional risk. Which is why, when I read a headline stating that the Swedish legal system was being exploited to commit money laundering, quite a discussion was sparked.
Be a learn-it-all
CEO Satya Nadella made the news last year when he revealed the secret of improved culture at Microsoft over the last few years has been down to the embracing of a learn-it-all culture.....More
Fuzzy matching: Getting the balance right
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?
Biometrics, cash and the end of money laundering as we know it?
As the technology to facilitate cashless transactions becomes more widespread, it can play an important role in know-your-customer and anti-money laundering efforts.....More
Five key points of the upcoming Fifth Anti Money Laundering Directive (5AMLD)
What is the 5AMLD? 5AMLD is a bit of misnomer, as it is in fact a set of proposed amendments to the Fourth Anti Money Laundering Directive (4AMLD) which is to be transposed on 26th June 2017. These proposed amendments were published in July 2016 as a way of strengthening the 4AMLD in light of recent terrorist attacks in Europe.
Brexit, Fintech and Big Data: Joining the dots in Ireland
It is fascinating how apparently unconnected points can be linked to reveal compliance challenges and opportunities. How, for example, does Brexit connect us to AML regulations, FinTech and Big Data in Ireland?....More
Is your client a money launderer?
Googled it? We offer insight to firms who vet their customers for ‘negative news’ or ‘adverse information’ through various methods of screening.
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?....More
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.
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
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.
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
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.
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
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
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!
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.
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.....More
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.
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
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.
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.....More
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.
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.....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:
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.....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:
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
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
AML and CTF: Are controls designed to mitigate risk also hampering firms?
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:....More
The winds of change have rolled in with the Asian Autumn
Since early October, students in Hong Kong have protested against China’s reneged promise of free and fair elections. This coming from the country who protested last when its citizens lost money en masse due to the misselling of minibonds in 2008. They used to say that HK only protests if the people lose their money. Clearly, this is no longer the case.
Calling Big Banks to aid financial inclusion and raise their social kudos
Last week, India’s Prime Minister Narendra Modi hit the headlines with his promise of bank accounts for every household in the country, a bid to offer help to the country’s poor. The initiative is part of a movement towards financial inclusion, which means making financial services accessible by people who do not have formal identification documents, fixed abodes or even known dates of birth.....More
Stick, twist or fold? How best to manage emerging trends and best practice in money laundering and t ...
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.
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