Compliance Officers Playbook

The UK's Financial Conduct Authority (FCA) has expressed concerns about banks' insufficient integration of Consumer Duty principles. They suggest that banks are not adequately embedding these principles across their operations. Instead, reliance is placed on risk and compliance teams to identify breaches. This indicates a failure to cultivate a company-wide culture that prioritises consume...

An example of a conflict during a SOC 2 audit finding discussion and analyses how it escalated. It highlights the importance of understanding differing perspectives, involving a neutral third party, and taking time to cool down before responding. The author suggests that emotional reactions may stem from unseen personal issues and encourages empathy. The core message centres around de-escalating c...

The Global AI Law Snapshot compares AI governance across the EU, China, and the USA. It focuses on legal instruments impacting organisations that develop and use AI. The document examines the presence of comprehensive and narrow AI laws in each region. While the EU has the comprehensive AI Act, China is developing a national AI law, and the US relies on a patchwork of federal and state regulations...

The Financial Crimes Enforcement Network (FinCEN) has fined Brink's Global Services USA £29.2 million for wilful violations of the Bank Secrecy Act (BSA). Brink's failed to implement adequate anti-money laundering (AML) controls, allowing substantial currency shipments across the Southwest Border on behalf of risky organisations. Specifically, Brink's did not register as a money services business,...

In this episode, we dive into the world of cryptocurrency and financial crime, exploring key insights from a training manual developed by COPOLAD III and endorsed by the CFATF. We break down how cryptocurrencies like Bitcoin, Ethereum, and Monero are used in money laundering and discuss the challenges law enforcement faces in tracking illicit transactions. We also explore investigative techniques,...

This episode covers a research paper which assesses money laundering in Iran's economy from 1995 to 2022. Employing a novel combined method based on the capital flight approach, the study estimates a total of $553 billion laundered, averaging $20 billion annually. The highest amount occurred in 2011 ($55 billion), while the lowest was in 2001 ($4.8 billion). The findings highlight the signific...

This White House fact sheet from February 2025 details President Trump's renewed "maximum pressure" campaign against Iran.  The policy aims to prevent Iran from acquiring nuclear weapons , neutralise its terrorist network, and counter its aggressive weapons development.  This involves reinstating stringent economic sanctions , pursuing legal action against Iranian operatives within t...

The Isle of Man Financial Services Authority announced that MONEYVAL, a committee of the Council of Europe, will conduct an on-site evaluation of the Island's anti-money laundering (AML) and counter-terrorist financing (CFT) regime in October 2026. This sixth-round evaluation will have stricter compliance standards, demanding substantial evidence of the regime's effectiveness. Preparations...

We are covering recent ESMA supervisory document which  offers guidance to National Competent Authorities (NCAs) on the authorisation of Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCA). It outlines a  risk-based approach  to authorisation, detailing factors like size, complexity, and cross-border activity that warrant increased scrutiny. The briefing als...

This episode discusses the European Parliamentary Research Service (EPRS) which examines the European Commission's proposed directive on combating corruption. The directive aims to create minimum standards for criminalising corruption across the EU, updating fragmented legislation and incorporating international standards, particularly from the UNCAC. The EPRS briefing details the legislative...

A joint investigation reveals how US and EU shipping companies have profited handsomely from selling older oil tankers, which subsequently joined a "shadow fleet" facilitating Russia's oil exports despite sanctions.  This fleet, potentially involved in espionage , uses vessels re-flagged and re-named in countries without sanctions against Russia.  The investigation highlights a lucra...

This episode catalogs Euronext's investor relations, compliance, and corporate governance services. It covers software solutions for insider list management and whistleblowing reporting, ESG and investor engagement advisory services, and an eight-step compliance strategy focusing on risk assessment, employee training, and continuous monitoring. The article highlights severe financial penalties...

This episode discusses an article from  Sport in Society  examines the ownership structures of English Premier League football clubs, analysing their use of legal entities and offshore jurisdictions. The authors argue that these complex structures obscure beneficial ownership, increasing the risk of illicit financial activity, such as money laundering. They propose that the new UK independent foot...

This episode covers a recent paper from the European Data Protection Board (EDPB) that examines the interplay between data protection and competition law within the EU. It highlights the increasing importance of personal data in business models and argues for greater cooperation between data protection and competition authorities to ensure coherent and effective regulation. The paper analyses how...

Discussing a Consent Order which is issued jointly by the Federal Deposit Insurance Corporation (FDIC) and the Oklahoma State Banking Department to the Bank of Vici. The order addresses concerns about unsafe or unsound banking practices and regulatory violations identified by the agencies. To rectify these issues, the Bank of Vici is mandated to improve its capital ratios, enhance board oversight,...

This European Central Bank decision outlines rules for non-bank payment service providers (NB-PSPs) accessing Eurosystem payment systems and central bank accounts.  Key aspects  include establishing non-discriminatory access criteria, setting maximum holding limits for funds in these accounts to prevent misuse, and specifying penalties for non-compliance. The decision clarifies that central banks...

This episode presents a qualitative thematic synthesis of existing literature on Regulation by Design (RBD), focusing on its application within digital technologies. The authors identify core features of RBD—goals, regulators, regulatees, methods, and technologies—and distinguish three types of RBD practices: compliance by design, value creation by design, and optimisation by design. The analysis...

This episode covers a report from the Bank for International Settlements (BIS) which provides guidance on the governance and risk management of artificial intelligence (AI) adoption within central banks. It examines the benefits and use cases of AI across various central bank functions, alongside a comprehensive taxonomy of associated risks, including operational, security, ethical, and reputation...

This episode discusses the widespread issue of "debanking" in the cryptocurrency industry, where banks unjustly refuse services to crypto businesses. This often stems from banks' lack of understanding of cryptocurrency and risk management tools, leading to blanket rejections rather than proper risk assessments. The unfair treatment is highlighted through examples in the UK and US, co...

The Basel AML Index 2024 report, the 13th annual edition, assesses global money laundering risks.  It ranks countries based on five risk domains : AML/CFT/CPF framework quality, corruption and fraud, financial transparency, public accountability, and legal/political risks. Data from 17 sources informs these risk scores, creating an independent, data-driven assessment. The Basel Institute on Govern...

China's amended Anti-Money Laundering (AML) Law, effective January 1st, 2025, significantly strengthens its AML framework by aligning with Financial Action Task Force (FATF) standards. Key changes include extending AML obligations to Designated Non-Financial Businesses and Professions (DNFBPs), increasing penalties for non-compliance, and mandating a national Ultimate Beneficial Ownership (UBO...

Cipher Mining , a bitcoin mining company, received a  $50 million investment  from SoftBank, a major investor in the President Trump-announced  Stargate AI initiative . This investment signifies a growing trend of Bitcoin miners diversifying into  high-performance computing (HPC)  and  AI data center infrastructure , a move viewed positively by analysts at JPMorgan. The funding will support Cipher...

The primary focus is a High Court appeal concerning Dentons, a global law firm, and the Solicitors Regulation Authority (SRA). The SRA appeals a tribunal's decision that Dentons' inadvertent breach of Money Laundering Regulations did not constitute professional misconduct. The article also features news and blog posts about various legal topics, including firm acquisitions, B Corp status, and the...

This episode summarises recent developments in European Union sanctions, focusing on the fifteenth package targeting Russia, encompassing individual and entity listings, trade restrictions, and divestment measures. The sanctions extended to Belarus and North Korea, alongside actions addressing hybrid threats. Furthermore, the newsletter highlights new European Commission FAQs clarifying due dilige...

A 2024 year-end review of regulatory enforcement highlights a sharp rise in global fines, totalling $25 billion, primarily due to increased scrutiny of financial institutions and virtual asset service providers (VASPs). Europe led in the number of enforcement actions, while the United States imposed the largest single fine. The report underscores intensifying focus on fraud prevention, sanctions e...