by Ahsan Habib

Criminals have long been coming up with creative and innovative ways to launder their illicit funds. When they started exploiting video games to satisfy their bad intentions, we the Risk Managers thought, maybe this is their last unconventional way of wrongdoing. But our thought has been proven wrong. In reality, bad actors did not stop their ‘winning race’. Yes, I am pointing at video games and the chocolate industry. Bad actors did not even spare these innocent products; rather to some extents they put question marks on the faces of online video games and chocolates. Continue reading…

The Banca d’Italia announced today that the ban on onboarding new customers at ING Italy, imposed in March 2019 has been removed. The decision follows the comprehensive steps undertaken by ING Italy to strengthen its processes and management of KYC compliance risks. Following an inspection by the Banca d’Italia, which had identified shortcomings in AML processes, in March 2019 ING Italy was banned from taking on new customers. Existing customers in Italy have continued to be fully served throughout the period.  Continue reading…

An alleged criminal network of copyright infringement hackers was recently dismantled by US authorities and their counterparts in 18 countries where they also received a great amount of support from Eurojust and Europol. This criminal network was known for pirating movies and distributing the illegal digital contents around the world. In a great coordinated effort, more than 60 servers were taken out of service in North America, Asia and Europe and several members of the criminal network were apprehended and taken in by the authorities. This crime group’s illegal activities ended up having significant negative effects, costing tens of millions of USD in losses annually to the US movie, television and other entertainment industries. Continue reading…

by Ahsan Habib

Sanctions cannot bring about success in isolation. The dialogue with the target country must be ongoing, both at the official and diplomatic level and via view exchanges with citizens and opposition groups in the target country. I would like to start with remembering the fairytale (which was quite familiar to me when I was a young child back home in Bangladesh) in which a little girl had a choice of three beds in which she could take a nap. The father’s bed was too hard, the mother’s was too soft, and only the baby bear’s bed was comfortable enough for her in which to fall asleep, finally she picked the bear’s one. Undoubtedly, those who impose sanctions should recall that Goldilocks (that little girl in the fairytale ‘Goldilocks and the Three Bears’) only slept soundly when she found the bed that was neither too soft nor too hard. Sounds weird at the beginning!! Trust me, it’s not weird, but rather relevant. Continue reading…

Recent research conducted by the Financial Conduct Authority (FCA) has revealed that approximately 2.6 million consumers in the UK have purchased cryptoassets at some point in time. This essentially marks an increase of 1.1 million since the FCA carried out a survey face to face on the same topic in 2019. Among the 1.9 million UK consumers that still have cryptoassets in their possession, such as Ripple, Ether, or Bitcoins, about half of them hold more than £260. This research conducted by the FCA is a part of its work with the Government and Bank of England in attempting to comprehend market size, profiles of consumers and what their attitudes are towards cryptoassets. Continue reading…

The European Commission last Friday referred Austria, Belgium and the Netherlands to the Court of Justice of the European Union, with a request for financial sanctions, for failing to fully implement the 4th Anti-Money Laundering Directive (AMLD4) into their national law. Executive Vice-President Valdis Dombrovskis said: “We have robust EU rules in place but they must be applied consistently and efficiently. We will make sure that everyone in both private and public sectors applies the rules rigorously. We have launched many infringement procedures to ensure the full transposition and application of our rules.”  Continue reading…

by Alex Movchan

We recently conducted another interview with Olga Lukashenko who is an Audit Director at Reanda Netherlands. The first interview that was conducted with this special woman can be found on our platform under related items, which was about planning and executing audit engagements during the Covid-19 crisis. This particular talk with Olga covers the topic of conducting audit engagements in regions with a high level of exposure to fraud and corruption.  Continue reading…

by Alex Movchan & Magdalena Wolska

“People show you who they are,
not by what they say, but by what they do.”
Jane Green, British journalist and writer

Probably, every internal auditor, at least once, had a feeling after the end of the audit engagement, that maybe there was something unnoticed, undiscovered, left “behind the curtains”. You start thinking about it, but nothing concrete really comes up on your mind – the interviews were held, reviews performed, testing completed. It looks like everything was examined properly, but the fear of missing something important just does not come out of the mind. Suddenly a thought comes up out of the blue: “And what, if there was a fraud out there?” Right, missing a fraud is the worst nightmare for an internal auditor. Although the Standards don’t put full responsibility of fraud detection on the internal auditors, but as is written in the Standard 1210.A2: “Internal auditors must have sufficient knowledge to evaluate the risk of fraud and the manner in which it is managed by the organization”. What is the trickiest about fraud is that it is like an iceberg – seems to be just a small detail from the first sight, but 95% of an iceberg is hidden beneath the water. And the damage it can cause might be truly unpredictable. If you have any doubts about that, just think about Titanic – the largest ship afloat with 2500 passengers on board, 1 500 of them died, making it one of the deadliest commercial peacetime maritime disasters in modern history. And this tragedy happened because the crew did not manage to identify the iceberg in time. 
Continue reading…

The Dutch Compliance Officers Association, abbreviated VCO, asked Geert Vermeulen to answer a number of questions about the COVID-19 crisis. Geert Vermeulen is a well-known Compliance Officer in the Netherlands, he also gives lectures and he teaches. Last year, he was the winner of the National Compliance Award 2019 (see photo). This prize is awarded annually with the aim of stimulating developments in the field of compliance, professionalising the compliance function and improving integrity within organisations. Geert was asked only three questions, but he answered them very thoroughly and extensively.  Continue reading…