Compliance Officers Playbook

The Financial Crime Guide (FCG) from the Financial Conduct Authority (FCA) offers practical guidance to firms on countering financial crime risks. It covers various crime types, including money laundering, fraud, bribery, and sanctions breaches, providing examples of good and poor practice. The guide emphasizes a risk-based approach, highlighting the importance of governance, risk assessment, poli...

The UK’s Financial Conduct Authority (FCA) annual report reveals that a significant majority (almost 90%) of cryptocurrency firm registration applications were rejected or withdrawn in the past year. The primary reason for rejection was the applicants' failure to meet adequate anti-money laundering and fraud prevention standards. Only a small fraction of applications were approved. Furthermore, th...

Meta's decision to replace its third-party fact-checking program with a community-based system, similar to that used by X (formerly Twitter), is the central focus of these sources. This shift, announced by Mark Zuckerberg, is attributed to a perceived "cultural tipping point" towards prioritising free speech and is seen by some as a move to appease the incoming Trump administration. Critics expres...

This episode covers a policy document from the International Chamber of Commerce (ICC) which provides guidance for small and medium-sized enterprises (SMEs) on conducting effective anti-corruption third-party due diligence. It highlights the increasing legal risks SMEs face regarding bribery and corruption, especially in international business. The guide details a six-pillar framework for investig...

This podcast episode discusses the often-overlooked importance of GRC architecture in achieving effective governance, risk, and compliance. It highlights how siloed GRC teams, focusing on separate risk, compliance, and audit functions, lead to inefficiencies and prevent proactive risk management. The episode advocates for a centralised GRC architecture, integrating data and fostering collaboration...

The Office of the Comptroller of the Currency (OCC) issued a cease-and-desist order to Bank of America for deficiencies in its Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance programs.  The order mandates corrective actions , including hiring an independent consultant to review the bank's programs and investigate past suspicious activity reports.  This follows a trend of increase...

The episode argues that current anti-money laundering (AML) programmes in financial services are inadequate, focusing on superficial compliance rather than effective risk management. It highlights the inefficiencies and risks associated with this approach, such as wasted time on false positives and an inability to scale with business growth. The episode advocates for a proactive, data-driven strat...

This episode summarises a Moody's report on compliance and third-party risk management trends for 2024 and 2025. Key themes in 2024 included sanctions evasion, driven by the Russia-Ukraine war and increased US regulation, and a continued focus on anti-money laundering. Looking ahead to 2025, the report predicts a continued emphasis on sanctions compliance, enhanced supplier due diligence (particul...

This podcast episode categorises six types of hackers: black hats (malicious actors seeking personal gain), white hats (ethical hackers working to improve security), grey hats (operating in a legal grey area), red hats (vigilantes targeting cybercriminals), blue hats (hired testers or those seeking revenge), and green hats (inexperienced learners). The episode explains the key traits and motivatio...

The UK's National Crime Agency (NCA) uncovered a massive, complex money-laundering operation, codenamed Operation Destabilise.  Starting with a ransomware investigation , the NCA traced funds through cryptocurrency to a Russian-speaking network linked to street-level drug dealing, sanctioned Moscow elites, and even Kremlin espionage.  The investigation revealed a sophisticated cash-for-crypto sche...

This podcast episode explains the importance of a risk register as a crucial tool for effective risk management. It defines a risk register as a dynamic document that identifies, assesses, and tracks organisational risks. The episode details key components of a risk register, including risk description, owner, likelihood, impact, mitigation strategy, residual risk, and monitoring. Practical applic...

This episode details a methodology for modelling and evaluating risk, focusing on the interplay between qualitative and quantitative methods. A key component is a risk matrix, using both numerical and descriptive risk levels, allowing for communication with both senior management and other stakeholders. The system facilitates the aggregation and prioritisation of risks and adapts to changing risk...

This podcast episode explains how financial institutions should effectively implement a risk-based approach to compliance. The episode outlines a four-step framework: identifying and assessing risks, making informed decisions about managing them, documenting those decisions, and continuously monitoring and reporting. It highlights challenges, such as difficulties in risk identification, data gaps,...

The episode highlights the urgent need for digital resilience in financial institutions, particularly in light of a recent cyberattack and the upcoming enforcement of the Digital Operational Resilience Act (DORA) on 17th January. It stresses that true resilience goes beyond mere compliance, requiring the integration of robust practices and proactive strategies. The author encourages organisations...

A podcast episode discusses a SecurityScorecard report revealing that only 26% of Europe's top companies achieved an "A" rating in cybersecurity, highlighting the looming Digital Operational Resilience Act (DORA) deadline of January 2025. The report underscores the critical importance of robust cybersecurity, especially in managing third-party risks, with significant disparities noted across secto...

This podcast episode discusses the Financial Action Task Force's (FATF) multi-pronged approach to improving beneficial ownership (BO) transparency. Companies must maintain accurate BO records, while governments should establish central BO registries. Financial institutions play a crucial role through rigorous customer due diligence and reporting discrepancies. This enhanced transparency is vital f...

This podcast episode examines the UK Financial Conduct Authority's (FCA) feedback on cryptocurrency firm applications for anti-money laundering (AML) and counter-terrorist financing (CTF) regimes. The episode highlights successful application characteristics, including robust AML/CTF frameworks, thorough risk assessments, and effective transaction monitoring. Conversely, it details common applicat...

This podcast episode examines the shortcomings of current anti-money laundering (AML) measures. It highlights the low global asset recovery rate (less than 2%), explores the reasons behind this, and discusses the FATF's shift towards prioritising asset recovery. The episode then debates whether focusing on asset recovery is more effective than stricter legislation, offering practical takeaways for...

This episode recounts the author's personal experience with fraud, stemming from their parents' criminal histories. One parent embezzled funds out of a need to help others, highlighting the complex relationship between poverty and crime, while the other parent committed tax fraud driven by greed. The author's firsthand exposure to the devastating consequences of both scenarios, coupled with a comm...

The episode outlines key regulatory priorities for 2025, focusing on enhanced transparency and accuracy in financial products and services. It emphasises consistent application of regulations across the consumer lifecycle, from product design to post-sales service. The emphasis is on fair and balanced representations to consumers, including scrutiny of marketing claims, endorsements, and fee struc...

The episode discusses the challenges regulators face in adapting to the rapidly evolving financial landscape. Increased innovation, particularly in areas like cryptocurrencies and digital assets, necessitates expanding the regulatory perimeter to ensure consumer protection and national security. This involves applying existing rules to new entities and products, as well as scrutinising new technol...

This episode details crucial aspects of a robust fraud risk management program. Internal controls, encompassing data tracking, authorisation processes, and multi-factor authentication, are highlighted as key preventative measures. The importance of proactive risk management, including regular updates and assessments, is emphasised. Furthermore, the episode stresses the need for effective resolutio...

This podcast episode discusses the increasing importance of exposure sizing in a rapidly evolving digital risk landscape. It highlights the growing regulatory focus on fraud, data breaches, and data privacy issues stemming from new technologies like AI. The episode emphasises the need for robust internal controls, including strengthened data access, updated consent frameworks, and validated third-...

The episode outlines crucial aspects of fraud prevention and detection for companies, focusing on regulatory expectations. Key areas highlighted include proactive fraud identification through monitoring systems and complaint analysis, robust internal controls, and effective oversight mechanisms involving boards and various departments (AML/CFT, cybersecurity). The emphasis is on timely responses t...

This episode outlines a nine-step plan for establishing a robust compliance function within a European market. The strategy, termed a "walking backwards" approach, prioritises achieving a fully integrated compliance system by first defining the desired end goal and then working backward to identify and mitigate potential challenges. Each step details specific actions, target outcomes, and key stak...