Compliance Officers Playbook

In this episode, we unpack the major enforcement action taken against Morgan Stanley after Dutch authorities uncovered its role in coordinated tax evasion schemes. Following extensive audits and criminal investigations, regulators issued a €101 million fine—the maximum possible—after determining that the firm used complex trading and derivative strategies to exploit dividend withholding tax rules....

In this episode, we explore the ideas behind “Compliance: Quiet Failure, Safe Guardrails,” a compelling look at how organisational breakdowns rarely result from one dramatic event. Instead, they stem from small, repeated oversights—missed documentation, ignored red flags, and routine shortcuts—that quietly stack up until they explode into full-blown regulatory failures or reputational crises. We d...

In this episode, we break down the landmark €21.5 million fine issued to Coinbase Europe Ltd by the Central Bank of Ireland—a ruling widely seen as a preview of what’s to come under the EU’s new Anti-Money Laundering Authority (AMLA). We explore how systematic coding errors left Coinbase’s transaction-monitoring system ineffective for nearly four years, allowing more than 30 million transactions t...

In this episode, we unpack the increasingly complex landscape of the EU’s digital regulatory regime—one that continues to evolve around the foundations set by the General Data Protection Regulation (GDPR). Drawing on recent analyses, we explore how regulators are sharpening their enforcement approach, applying strict criteria that can lead to fines of up to four percent of a company’s global turno...

In this episode, we dive into Wise’s major move into the African market, starting with its newly launched operations in South Africa. After securing conditional approval from the South African Reserve Bank to operate as a regulated foreign-exchange dealer, the London-based fintech is taking a significant step toward transforming one of the world’s most important remittance corridors. We break down...

In this episode, we break down the Australian Institute of Criminology’s latest statistical report on the true economic toll of serious and organised crime in Australia during the 2023–24 financial year. The headline figure is staggering: an estimated upper cost of $82.3 billion , a sum that accounts for a significant slice of the nation’s GDP. We explore how this massive total is calculated—combi...

In this episode, we unpack Transparency International UK’s 2025 assessment of how the UK’s Overseas Territories are progressing—or failing to progress—on creating accessible registers of beneficial ownership. These registers are meant to shine a light on who really owns companies, a crucial step in fighting global illicit finance. But as the report reveals, the reality is far more complicated. We...

In this episode, we break down the major political agreement just reached by EU lawmakers on two transformative pieces of legislation: the Payment Services Directive 3 (PSD3) and the new Payment Services Regulation (PSR). Together, these measures set the stage for a modernized, fairer, and more transparent financial ecosystem across Europe. We explore how the deal aims to crack down on fraud, intr...

In this episode, we dig into the new civil lawsuit recently filed by American citizens against Changpeng Zhao (CZ) and Binance. The plaintiffs — family members of victims killed or taken hostage during the October 7 attacks — accuse CZ and Binance of knowingly facilitating the movement of millions of dollars to designated militant organisations, including Hamas and Hizbollah, even after Binance’s...

In this episode, we explore the UK Financial Conduct Authority’s evolving approach to crypto regulation, drawing on key excerpts from the FCA’s mandate and a keynote speech by Executive Director David Geale. We break down the FCA’s vision for building a trusted, competitive, and innovative market for cryptoassets and stablecoins—one that doesn’t simply copy traditional finance rules but instead re...

In this episode, we examine the story behind a major regulatory enforcement action in Luxembourg’s financial sector: the €283,000 administrative fine imposed on Allianz Global Investors’ Luxembourg branch for persistent anti-money laundering (AML) and counter-terrorist financing (CFT) failures. We unpack the findings of a 2018 CSSF inspection that uncovered serious gaps—including the omission of m...

In this episode, we break down a sweeping Statutes Amendment Bill—an omnibus legislative package crafted to update and refine large sections of the existing legal framework. Spanning 42 separate parts, the Bill reaches across a wide array of principal Acts, making it one of the most comprehensive housekeeping efforts in recent legislative cycles. We walk through the key areas of reform, from envir...

n this episode, we unpack a deep-dive analysis from the European Parliament’s Economic Governance and EMU Scrutiny Unit (EGOV) on one of the EU’s most significant reforms in financial oversight: the creation of the European Anti-Money Laundering Authority (AMLA). We explore how the EU’s 2024 AML/CFT package—including the new Anti-Money Laundering Regulation (AMLR), the Sixth AML Directive (AMLD6),...

In this episode, we dive into a landmark enforcement action from the U.S. Treasury’s Office of Foreign Assets Control (OFAC): the largest financial penalty ever issued against a single individual. The $4.67 million fine stemmed from a real estate professional who intentionally carried out a series of transactions involving a property tied to a sanctioned Russian oligarch—despite explicit notice th...

In this episode, we break down the real—and often misunderstood—world of sanctions risk for financial institutions. Forget the idea that simply avoiding certain correspondent relationships will keep a bank safe. As we explore in depth, sanctions exposure is far more complex, encompassing secondary sanctions, reputational damage, and the growing reach of extraterritorial enforcement. We look at rec...

In this episode, we unpack the crucial difference between two very different leadership approaches to corporate integrity: “Tone from the Top” vs. “Orders from the Top.” Inspired by a recent article from Wael Al Halabi, we explore why a genuine, values-driven tone set by the board isn’t just good governance — it’s an organisation’s strongest defence against compliance failures and financial crime....

In this episode, we dive into the high-pressure world of the Money Laundering Reporting Officer — a role that’s essential to protecting financial institutions, yet often misunderstood and overlooked. Drawing on recent insights, we explore why MLROs carry such an immense burden, how regulatory expectations can clash with limited resources, and why compliance is still too often viewed as a commercia...

In this episode, we explore how Artificial Intelligence (AI) is reshaping the internal audit profession. While there’s widespread agreement that AI won’t replace human auditors, it’s clear that it will transform their roles. We look at real-world perspectives from auditors who are already using AI to automate repetitive tasks like risk assessments and report drafting, freeing up time for more comp...

The FATF (Financial Action Task Force) Toolkit provides a comprehensive framework for conducting National Risk Assessments (NRAs) on money laundering (ML) , terrorist financing (TF) , and proliferation financing (PF) . It includes practical quick guides for evaluating complex areas such as corruption , virtual assets (VAs) and virtual asset service providers (VASPs) , legal persons and arrangement...

In this episode, we explore the evolving role of Internal Audit under the Global Internal Audit Standards (GIAS 2024). Once seen primarily as a compliance checkpoint, internal audit is now transforming into a strategic, forward-looking partner within organisations. We discuss key shifts, including moving from static annual plans to agile, rolling models and transitioning from simply reporting prob...

In this episode, we explore the complex and often uncomfortable world of risk management, especially for those with a perfectionist mindset. Unlike compliance, which operates with clear rules and definitive answers, risk management lives in the grey areas of uncertainty. We discuss why business growth actually depends on embracing this uncertainty rather than trying to eliminate it. The episode hi...

In this episode, we dive into Switzerland’s heated debate over proposed anti-money laundering (AML) reforms driven by FATF recommendations . Lawmakers are pushing back against stricter rules for lawyers, advisers, and trusts, arguing that excessive regulation could weaken Switzerland’s financial competitiveness and autonomy. This resistance comes despite warnings from the Federal Department of Fin...

In this episode, we examine the corruption and money laundering case involving Georgia’s former Defense Minister, Juansher Burchuladze . According to investigators, Burchuladze abused his authority in 2023 by orchestrating a non-competitive procurement of medical equipment, inflating prices for personal and family gain, and causing more than 1.3 million GEL in losses to the Ministry of Defense. To...

In this episode, we explore a recent advisory from the Financial Crimes Enforcement Network (FinCEN) on the growing threat of Chinese Money Laundering Networks (CMLNs) . These networks play a key role in moving illicit funds, including those connected to cartels involved in fentanyl production. We break down FinCEN’s guidance for U.S. financial institutions, including how to detect and report susp...

In this episode, we cover the recent case of Dutch neobank Bunq, which has been fined €2.6 million by the Dutch central bank for repeated failures in its anti-money laundering (AML) controls. Despite prior warnings and interventions, Bunq reportedly fell short in investigating suspicious transactions and applying adequate scrutiny to certain customers across multiple cases. This enforcement action...