FINANCIAL CRIME

Free for all

If I were sitting in a mountain-top lair, twirling my moustaches and cackling evilly, I don’t think I could devise an environment more conducive to financial crime than the UK in late 2020.  Put to one side the spinelessness of … Continue reading

Ethics girls and boys

With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind.  I come from mixed stock: one half of … Continue reading

Latest leak lessons

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”.  I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading

Sixth sense

Right, here’s a little quiz for you: as of today, it’s 78 days until what?  Points deducted if you simply say, “Thursday 3 December” – although points added if you know that that’s my mother-in-law’s birthday [note to self: remind … Continue reading

AML for the autodidact

I’m a big fan of surveys and reports: give me a sniff of a group of compliance types being asked for their take on AML, and I’m there with my hand in the air, begging for the results, like the … Continue reading

COMPLIANCE

Smith and Ricardo: Classical Economists and the Origins of TBML

Economics has been labeled a “dismal” science for a variety of reasons, so it should not be surprising that an economist would take advantage of the current pandemic stay-at-home orders to read what some would consider dreary works: Adam Smith’s The Wealth of Nations (1776) and David Ricardo’s On the Principles of Political Economy and...

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Evaluating the Risk-Based Approach

The risk-based approach (RBA) is an essential component to implementing the Financial Action Task Force’s (FATF) Recommendations effectively. Financial institutions (FIs) are expected to identify, assess and understand the money laundering and terrorist financing risks to which they are exposed and take anti-money laundering/counter-terrorist financing (AML/CTF) measures commensurate to those risks to mitigate them effectively....

The post Evaluating the Risk-Based Approach appeared first on ACAMS Today.

What’s Blockchain Analysis? — A Descriptive Guide

What is Blockchain Analysis? — A Descriptive GuideOriginally published in the NOWNodes blog.Blockchain analysis has emerged as a big business over the past few years. The U.S. Government reportedly spent $6 million to carry out blockchain analysis acti...

Criminal Ploy or Jackpot Joy?

As there is a paucity of empirical data on money laundering and terrorist financing in the United Kingdom’s (U.K.) online gaming sector, the evidence of actual criminal use in this industry remains sparse. The following Metropolitan Police Service (MPS) analysis seeks to address this issue by comprehensively evaluating 157 suspicious activity reports (SARs) provided by...

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Render Unto OFAC

When the U.S. Congress enacts sanctions by passing legislation, it is often unwelcome by the executive branch. Such legislation can restrict the flexibility and autonomy of the executive branch in responding to changed diplomatic circumstances when trying to advance U.S. foreign policy goals. That was certainly the case during the Obama administration, whose ability to...

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ANTI CORRUPTION

Judge Tosses FCPA Jury Verdict

On February 26, 2020, Judge Janet Bond Arterton, a federal judge for the District of Connecticut, overturned a former Alstom SA executive’s conviction under the Foreign Corrupt Practices Act (FCPA) relating to a project to build power plants in Indonesia. Judge Arterton found that, despite a jury verdict to the contrary, prosecutors failed to prove...… Continue Reading

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Linguistic Clues Narrow Identity of Country A in Mueller Probe

Fascination continues about the identity of Country A in Special Counsel Mueller’s investigation into Russian interference.  An unidentified corporation is a witness in the investigation and is owned by Country A. Recent developments provide clues in the unredacted portions of unsealed court rulings and party filings.  Based on linguistic analysis of court rulings and pleadings, Kristina...… Continue Reading

Will Russia Provide Missing Links to Murder, Kickbacks, Bribery?

The case against Leonid Teyf, a Russian citizen, in a federal court in North Carolina has enough juicy facts for an international crime novel. The U.S. prosecutors need evidence to convict Teyf and his accomplices of the central charges, stemming from an alleged kickback scheme in Russia. Will Russia provide missing links? U.S. v. Teyf,...… Continue Reading

Circuit Rejects Expansive Use of Conspiracy for FCPA

The Second Circuit issued its judgment on the case we have been monitoring, U.S. v. Hoskins. The court held that the “government may not expand the extraterritorial reach of the FCPA by recourse to the conspiracy and complicity statutes.” DOJ Theory Rejected The holding is of significant interest as it narrows the DOJ’s jurisdictional reach over...… Continue Reading

The Yacht Equanimity: a Symbol of Corruption?

This month, former Malaysian Prime Minister Najib Razak, who served from 2009 to 2018 as Malaysia’s sixth Prime Minister, pleaded not guilty to three new money-laundering charges related to the alleged multibillion-dollar looting of 1Malaysia Development Berhad (“1MDB”), a Kuala Lumpur-based strategic development company that is wholly owned by the Malaysian Ministry of Finance. The...… Continue Reading

DPA Regime a Landmark Change to Singaporean Law

A recent landmark change to Singapore’s criminal justice system providing for Deferred Prosecution Agreements (“DPAs”), or voluntary alternatives to adjudication, should increase corporate accountability for acts of bribery, corruption, and money laundering. DPAs a Dual-Purpose Enforcement-Prevention Tool DPAs provide a powerful enforcement tool for prosecutors seeking to hold accountable companies that commit crimes and to...… Continue Reading

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CORRUPTION

Latest leak lessons

Keep washing that money

I beg your pardon

Free for all

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EXCLUSIVE

Evaluating the Risk-Based Approach

The risk-based approach (RBA) is an essential component to implementing the Financial Action Task Force’s (FATF) Recommendations effectively. Financial institutions (FIs) are expected to identify, assess and understand the money laundering and terrorist financing risks to which they are exposed and take anti-money laundering/counter-terrorist financing (AML/CTF) measures commensurate to those risks to mitigate them effectively....

The post Evaluating the Risk-Based Approach appeared first on ACAMS Today.

E-KYC in the Digital Era

Although consumers and businesses are moving their financial activities online, digital onboarding is hampered by regulations, legacy systems and a disjointed approach for applying customer due diligence (CDD) and know your customer (KYC) controls in online or in-app environments. This article looks at how compliance teams can adapt to a digital environment and perform e-KYC—completely...

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Virtual Currencies—Regulation and Terrorist Financing Risks

The rise of bitcoin and other virtual currencies poses new challenges in the fight against money laundering and terrorist financing (ML/TF). With virtual currencies, users can make global payments that are beyond the control of financial regulators and security authorities.1 In addition, there is a growing risk of terrorist financiers evading state surveillance and tapping...

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INTERVIEWS

Mia Lee: Women Are Up to the Challenge

In honor of Women’s History Month, ACAMS Today’s Community Banking Corner column is profiling women in the world of community banking. Mia Lee has worked in the banking and financial services industry since 1989, focusing on Bank Secrecy Act/anti-money laundering (BSA/AML) practices since 2002. She is currently the compliance and Bank Secrecy Act (BSA) officer...

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Candice Huggins: Recognizing Women’s Daily Contributions

For International Women’s Day 2020, ACAMS Today had the pleasure of interviewing Candice Huggins, chief compliance officer at CIBC FirstCaribbean International Bank, about her career, her role as a woman in anti-money laundering (AML), and what she is doing to make an impact in this industry and her community. Huggins’ experience spans over 20 years...

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Stacey Ivie: Promoting the Spirit of the Law

For International Women’s Day 2020, ACAMS Today  chatted with Stacey Ivie, detective for the Alexandria Police Department who holds a Special Deputation with the U.S. Marshals Service, to discuss her career in law enforcement. Ivie is currently assigned as a task force officer (TFO) to the Washington Baltimore High Intensity Drug Trafficking Area (HIDTA) Northern...

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Marina Adams: Networking in the Workplace

ACAMS Today  spoke with Marina Adams,1 compliance officer and assistant vice president of the Federal Reserve Bank of New York (NY Fed), to discuss career advice and equality in the workplace. Adams helped create and develop the compliance function of NY Fed. Adams’ responsibilities include the development and implementation of the anti-money laundering (AML) and...

Deborah Lehr: Think Big, Why not? You Never Know What You Might Achieve

ACAMS Today  sat down with Deborah M. Lehr, to speak about her background, professional experience and her passion to protect human heritage. Lehr is chairman and founder of the Antiquities Coalition. Lehr is an accomplished global business strategist who has supported leading global firms and organizations to grow their presence in the world’s most complex...

Lisa W. Wardell: The Importance of Mentorship and Diversity

ACAMS Today  had the privilege to speak with Lisa W. Wardell, president and CEO of Adtalem about her background, professional experience and what it means to break boundaries as the only African-American female CEO in the S&P 400. Wardell is a philanthropist, mother of six, wife, mentor, sponsor and CEO. She was appointed president and...

AUTOMATION

ML Dashboards: Driving Insight From AI-Powered Fraud Analytics

Machine learning (ML) sits at the heart of advanced fraud prevention platforms like Simility, a PayPal Service. But there’s a difference between boasting of the technology on a specs sheet and delivering it in a meaningful way for users. Data scientists and in-house fraud teams are in short supply today, making it vital that organizations […]

Decentralized ML: Part I (Introduction)

The first part of the decentralized machine learning series focuses on understanding the need for decentralization using an intuitive example.Photo by Clint Adair on UnsplashThis is the first part of the series of blogs on the topic of Decentralized Ma...

Decentralized ML: Part II (Blockchain Basics)

The second part of the decentralized machine learning series introduces the basic concepts of blockchain, a tool used for decentralization.Photo by Launchpresso on UnsplashThis is the second part of the series of blogs on the topic of Decentralized Mac...

How to Stop Account Takeover Attacks in Their Tracks

Twenty-first century consumers live much of their lives online. To do so, they open accounts with a variety of internet-based companies — everything from banks, insurers, and social media providers to e-commerce stores. This makes life easier, with car...

Overcoming The Challenge Of Bias And Discrimination In Machine Learning

After Phillip Alston, UN rapporteur on poverty and human rights, presented his report to the UN a few weeks ago, the machine learning (ML) community sat up and took notice. In his report, Alston pointed out how new technologies revolutionize the intera...

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