Compliance Officers Playbook

In this episode, we examine the ongoing criminal investigation into Roman Abramovich, former owner of Chelsea FC, led by Jersey authorities. The probe focuses on allegations of corruption and money laundering tied to the origins of Abramovich’s wealth, particularly his multibillion-dollar sale of oil and gas giant Sibneft in 2005. Swiss courts have ordered the release of key banking documents to a...

In this episode, we introduce the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), the European Union’s new decentralised agency designed to harmonise and strengthen AML/CFT supervision across member states. We explore AMLA’s core functions, including direct oversight of high-risk financial entities, coordination of national financial intelligence units (FIUs),...

In this episode, we unpack the multifaceted world of dormant accounts—what they are, the risks they pose, and how they’re managed across different contexts. We explore best practices for identifying and securing inactive accounts, from fraud prevention to working with executors, while addressing potential risks like identity theft, unexpected fees, and credit score impacts. We highlight the UK’s D...

In this episode, we cover a recent enforcement case from the UK’s Financial Conduct Authority (FCA) involving the conviction of Daniel Pugh, who ran the £1.3 million Imperial Investment Fund—a Ponzi scheme that defrauded 238 investors. Largely promoted through Facebook, the scheme lured victims with promises of unrealistic daily, weekly, and annual returns. We discuss the charges brought against P...

In this episode, we shine a spotlight on major financial crimes—money laundering, fraud, bribery, corruption, and market abuse—unpacking their definitions, common perpetrators, and methods, including the three-stage laundering process of placement, layering, and integration. We examine why certain financial products and corporate structures are especially vulnerable, and how strong measures like c...

In this episode, we focus on the real-world application of Governance, Risk, and Compliance (GRC) within organisations. We break down what effective GRC looks like in practice, exploring the standards that guide firms in building strong controls and demonstrating the value of well-implemented frameworks. The episode highlights the vital roles and responsibilities of compliance functions and profes...

This episode provides an overview of the Travel Rule's implementation across various global jurisdictions. The Travel Rule requires Virtual Asset Service Providers (VASPs) to share customer data during virtual asset transfers to combat money laundering and terrorist financing. Different countries have established varying thresholds, some having zero-threshold rules where all transactions are subje...

The European Commission published guidelines in 2025 outlining prohibited artificial intelligence (AI) practices as defined by Regulation (EU) 2024/1689 (AI Act).  These guidelines clarify the Commission's interpretation of Article 5 of the AI Act, ensuring consistent application across member states from February 2025.  The document details specific AI practices considered harmful and in violatio...

The Financial Conduct Authority (FCA) examined ongoing financial advice services to ensure consumers receive the services they pay for.  The review analysed data from 22 firms regarding suitability reviews, finding they were mostly delivered.  However, some clients declined reviews, and a small percentage of firms failed to offer them, raising concerns.  The FCA expects firms to rectify any shortc...

Covering an article from Merkle Science reports on a $1.5 billion hack of the Bybit cryptocurrency exchange, highlighting vulnerabilities in multi-signature cold storage.  The attackers manipulated the user interface of transaction verification tools, causing operators to unwittingly authorise a malicious transfer, and the stolen funds were then laundered through complex methods including DEXs, ad...

The European Union has enacted significant sanctions against Russia  in response to human rights abuses, its aggression against Ukraine, and hybrid threats.  These measures specifically target individuals and entities responsible for severe human rights violations , the repression of civil society and democratic opposition, and those undermining the rule of law.  Sanctions include travel bans, ass...

This Episode covers the the European AI Office's repository of AI literacy practices, which is intended to help companies comply with EU regulations.  It highlights limitations of the repository, such as the vague descriptions and KPIs, the broad size and sector categorisations, and its non-recommendatory nature. 

This research from CEPII examines the economic impact of sanctions on Russia, particularly concerning strategic and dual-use goods. Sanctions do not entirely block access to these items, but they do increase import prices, especially from non-sanctioning countries. The price index of Russian imports saw a notable jump after sanctions were implemented. Strategic goods have experienced a particularl...

A law firm, WGS Solicitors, and one of its partners, Bridget Catherine Miller, have been penalised by the Solicitors Disciplinary Tribunal (SDT) for breaches of anti-money laundering regulations.  The firm admitted to failures, including improper handling of client funds and inadequate customer due diligence between 2017 and 2021.  WGS Solicitors received a fine of £25,258, while Miller was fined...

FinCrime Central reports that the UK Gambling Commission is concerned about the gambling industry's AML compliance, highlighting failures in scrutinising customer data and verifying the source of funds.  The rise of AI-generated fake documents and cryptocurrency use for illegal transactions are significant emerging threats.  The Commission is piloting financial risk assessments and collaborati...

The White House document details an executive order mandating increased Presidential oversight of independent regulatory agencies.  This order seeks to ensure these agencies are accountable to the President and, through him, to the American people, by requiring regulatory actions to be reviewed by the Office of Information and Regulatory Affairs (OIRA).  The Government Executive article reports on...

A recent executive order signed by President Trump has paused future investigations and enforcement actions related to the Foreign Corrupt Practices Act (FCPA).  This order directs the US Attorney General to revise FCPA guidelines, potentially prioritising American economic interests and foreign policy objectives. While the FCPA itself remains law, this halt could create uncertainty, particularly...

The episode highlights a shift in global anti-corruption efforts, spurred by the US's recent decision to retreat from this arena.  It argues that the UK must now step up, filling the void left by the US, which was historically a leader in combating financial crime and kleptocracy.  The piece criticises the UK's past involvement in facilitating corruption through tax havens and anonymous sh...

Hong Kong's Securities and Futures Commission (SFC) has released a regulatory roadmap called "A-S-P-I-Re" to future-proof the region's virtual asset ecosystem.  This framework, detailed in the document, addresses the complexities of the virtual asset market, valued at over US$3 trillion, and the need for balanced regulation.  The roadmap's five pillars - Access, Safeguards, P...

Criminal elements are increasingly exploiting cryptocurrency platforms , utilising sophisticated technologies like AI to perpetrate fraud and launder illicit funds.  Regulators worldwide are responding  with increased scrutiny and enforcement actions against crypto exchanges, particularly concerning anti-money laundering compliance.  AUSTRAC, the Australian financial crimes regulator, has put nume...

An OCCRP investigation reveals how the family of Azerbaijan's president used offshore trusts to conceal ownership of hundreds of millions of dollars worth of London properties. Despite UK transparency reforms aimed at exposing such practices, loopholes, particularly those involving trusts, allow the ultimate beneficiaries to remain hidden. While some properties' ownership is now public, others rem...

AUSTRAC, the Australian financial crimes regulator, is scrutinising cryptocurrency exchanges due to concerns about money laundering and the financing of illegal activities.  The regulator has issued notices to 50 exchanges suspected of failing to report suspicious transactions and has already taken action against several firms.  These actions include deregistering some exchanges and imposing condi...

The Council of the European Union updated its list of non-cooperative tax jurisdictions, retaining the same 11 nations previously identified.  The update acknowledges cooperative efforts from some jurisdictions to improve tax governance.  Costa Rica and Curaçao were removed from a monitoring document after addressing deficiencies in their tax information exchange.  Brunei Darussalam has committed...

FinCrime Central reports the arrest of former Mauritius Prime Minister Pravind Jugnauth amidst a money-laundering scandal.  The article details allegations of financial irregularities, police raids uncovering incriminating evidence, and the potential misuse of political power.  It examines the political repercussions for Mauritius, which includes scrutiny of his legacy and the country's ongoin...

Increased scrutiny of shadow fleets  is causing waves in marine re/insurance as regulatory bodies intensify sanction enforcement, particularly concerning Russian oil.  Ship-to-ship oil transfers  and opaque ownership structures are key evasion tactics under watch.  Flag states and international bodies  are taking action, with Panama deregistering vessels and the EU expanding sanctions.  The US  is...