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Confronting invisible (and visible) aggressors in a changing landscape

31 March 2020
Knowledge Base

by Ahsan Habib

The coronavirus (COVID-19) outbreak is causing widespread concern and economic hardship for consumers, businesses and communities across the globe. The situation is changing quickly with widespread impacts. Cyber hackers hit the U.S. Health and Human Services Department with an attack few days back during a presentation and update on the nation’s response to the coronavirus pandemic. Historically these criminals and hackers are as callous as they are opportunistic. We must also be wary of official-looking emails telling bank/FI staff to click on a link to learn more about how to stop the spread of the virus. Financial Crime Watchdogs across the globe has already warned about skimping on Anti Money Laundering and advised to be wary of the incoming flood of fraud. Financial institutions have been advised to remain alert about malicious or fraudulent transactions similar to those that occur in the wake of natural disasters. 
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Crowdfunding – an overlooked aspect of Money Laundering

14 January 2020
Knowledge Base

by Ahsan Habib

It seems to be a reasonable enough assumption that a dedicated money launderer would be able to utilise crowdfunding to wash their dirty money.The features facilitating the exploitation of crowdfunding for money laundering include the lack of legal regulations imposing a direct obligation to identify clients of crowdfunding platforms, as well as the absence of supervision of their activities. This can generate such threats as the mingling of income from legal and illegal sources, transferring criminal proceeds to persons conducting crowdfunding, and legitimating assets through the organisation of crowdfunding campaigns.
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Money Laundering in Canada: More unknowns than knowns

30 December 2019
Knowledge Base

by Ahsan Habib

Canada has become a well-known target, even a magnet, for money laundering. Ironically once a Canadian has the legal right of ownership, the law firmly protects that right. For that reason laundered money in Canada is much more valuable than dirty money elsewhere. And that is why money launderers are ready to pay well over asking for high-priced real estate, where multimillion-dollar blocks of cash can be cleansed in a single deal. The defining issue of our times must be who will stop these criminal predators from selling opioid, laundering the proceeds, buying up real estate and violating every conceivable aspect of Canadian sovereignty and the Criminal Code. Let’s go deeper into the ‘Rabbit Hole’….. Continue reading…

OFAC’s 50 percent rule: 50 percent of 50 percent is still 50 percent…

05 December 2019
Knowledge Base

Michel Klompmaker

On November 14, the first edition of the Augmenting Customer Due Diligence (ACDD) event was held at the Jaarbeurs in Utrecht. Compliance is certainly not a boring field and you must be fully familiar with what is possible and what is not allowed. No financial institution, large or small, appears to be immune to the threat of fraud or money laundering. This event was meant to examine how data and innovation can accelerate progress towards common goals, such as cost reduction and streamlining of the CDD (KYC) process. Continue reading…

Bulgarian Fintech discussed compliance and financial crime in Sofia

25 September 2019
Knowledge Base

by Elina Karpacheva

The Bulgarian FinTech community met to discuss compliance and financial crime for the first time in Sofia. The Spotlight event, organized by Eleven Ventures and the European Compliance Center was truly a success – an evening full of valuable insights and discussions between entrepreneurs and AML/financial crime specialists. The event showed that the thriving innovative ecosystem seriously takes into account the AML/financial crime risks and is committed to building effective internal systems for detection, prevention and response. The event coincided with the launch of the First Bulgarian FinTech report. Bulgaria is the fastest growing Fintech destination in the CEE region according to the newest CEE Fintech Atlas by the Raiffeisen Bank International (RBI).
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SBP’s Financial Stability Review for CY18: “The macroeconomic imbalances have impacted some segments of the financial sector”

09 September 2019
Knowledge Base

The State Bank of Pakistan (SBP) has imposed monetary penalties amounting to Rs 805 million on 10 banks in August 2019 for noncompliance of regulatory requirements. SBP has disclosed significant enforcement actions taken against banks in the last month aimed to bring more transparency and strengthen the market discipline. According to details issued by State Bank, cumulatively Rs 805.1 million monetary fines were imposed on ten banks during August 2019 for violating laws, rules, regulations, guidelines or directives.

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The future of the AML is in cryptocracy

22 August 2019
Knowledge Base

by Giacomo Luca Aleo

On June 18, 2019 Facebook announced the birth of its own cryptocurrency: Libra, whose name is inspired by Roman unit of measurement, deriving from balance Latin name; the debut is expected for the first half of 2020. The announcement caused, on one hand, a general uproar and, on the other, the value increase of the other cryptocurrencies. The “Libra Association” (no-profit organization) will manage Libra. It currently counts 28 heterogeneous founding partners (with the goal of reaching 100), representing business giants: from Mastercard and Visa to operators of payment system (PayPal, PayU, Stripe), from telecommunications operators (Vodafone and Iliad) to consumer companies (including Booking, eBay, Spotify, Uber), from venture capital such as Andreessen Horowitz to a global exchange Coinbase. Managing Libra actually means manage the Libra Blockchain: it is a permissioned ledgers model, i.e. the management and the validation of transactions is prerogative of a single node, which – in this case – is collective and represented by the Libra Association. The blockchain will record the entire history of the transactions by replicating them in the node; therefore, the transactions will be transparent to all participants of the Libra Association.
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SEC Obtains Freeze of $8 Million in Assets in Alleged Fraudulent Token Offering and Manipulation Scheme

19 August 2019
Knowledge Base

The Securities and Exchange Commission announced fraud charges against a Brooklyn individual and two entities under his control who allegedly engaged in a fraudulent scheme to sell digital securities to investors and to manipulate the market for those securities.  The court entered an emergency freeze to preserve at least $8 million of the $14.8 million the defendants raised in 2017 and 2018 in an offering of digital securities.
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Keeping one’s mind on financial crime: new risks, new opportunities

14 August 2019
Knowledge Base

by Elina Karpacheva

Innovation is surely a good thing. FinTech makes access to finance fast, easy and accessible which is of great benefit to individuals, households and businesses. However, the increased speed of initiating transactions, the borderless movement of money flows, and anonymity may be exploited for ill-gotten gains. FinTech might be used for terrorist financing, money laundering, fraud, tax evasion, market abuse, and overall undermine the stability of financial system. From this angle, FinTech companies have enormous responsibility towards the society to prevent fraudulent behaviour. Governments around the world have started recognising risks associated with technologically enabled financial innovation. In effect, we see the increased level of regulation with enforcement against the FinTech being one of the priorities. The need of FinTech companies to establish compliance expertise to prevent, detect, and response to financial crime has become apparent. 
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OCC – Fraud Risk Management Principles

06 August 2019
Knowledge Base

The Office of the Comptroller of the Currency (OCC) inform national banks, federal savings associations, and federal branches and agencies (collectively, banks) of sound fraud risk management principles. Fraud risk management principles can be implemented in a variety of ways and may not always be structured within a formal fraud risk management program. Regardless of the structure, fraud risk management should be commensurate with the bank’s risk profile. Banks with significant and far-reaching retail-oriented business activities should have well-documented fraud risk management programs with appropriate monitoring, measurements and reporting, and mitigation.

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