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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
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
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.
Financial inclusion, integrity and technology – a match made in heaven?
Where would we be without technology? It has become a fundamental part of many of our daily lives..... More
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.
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..... More
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.
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
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.
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)..... More
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.
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..... More
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...
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..... More
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.
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..... More
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.
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..... More
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.
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..... More
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.
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..... More
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...
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..... More
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.
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’..... More
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.
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..... More
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.
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..... More
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
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
Place your bets: The gaming industry and bookmakers - low risk for money laundering or not?
A debate is currently raging between the industry, policymakers, and regulators. The stakes are high indeed with the industry arguing disproportionate regulation could lead to hugely increased costs (in the millions of pounds) and job losses across the high street retail betting shop sector..... More
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.
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..... More
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.
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!.... More
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.
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
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.
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..... More
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
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..... More
Financial crime: Views on the news
LIBOR, conspiracy to defraud, the Bank of England, Barclays, Qatar, dual criminality and some other observations…….
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..... More
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.
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..... More
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
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