A wealth of information
In this episode we couldn't resist a deep dive into the recent UBS fine by four (yes, four) US regulators and what that means for anyone working in the Financial Crime Compliance space
SUBJECT COLLECTION
Detection & compliance
Due diligence, intelligence, risk and better decisions.
The questions behind the subject
A useful control begins with an understanding of the risk. Explore how customer assessments, business-wide assessments, intelligence and training connect to the decisions people make every day.
- Which risks arise from geography, products and delivery channels?
- How does customer risk connect to the business-wide assessment?
- Are controls helping people detect a problem or simply document a process?
SUGGESTED LISTENING SEQUENCE
Read the dates alongside the discussions: rules and investigations develop over time.
All episodes in this collection
Document or detect?
We take a look at the effect of human behaviour on our ability to stop criminals gaining access to the financial system and why that system is more likely to produce comprehensive documents than effective detection.
It's a grey(list) area
Today we tackle some colourful risk lists or, to be a bit more precise, some black and grey ones, along with some strange differentials. Like how come the UK has a high risk third country list when there are no second co…
The sharing of suspicion
SARs! Search and rescue services? Subject access requests? Sudden acute respiratory syndrome? No - suspicious activity reports! That's what we are talking about this time. And there's a lot more to them than you might th…
Don't let mules make an ass of your firm
In this episode we look at the FCA's latest thematic review of the National Fraud Database and money mule account detection tools and summarise what we think firms can take from it and what actions they might consider ta…
Financial Crime Training - Mind the gap!
We turn our attention to the requirement to train relevant staff on all matters anti-financial crime. And if you're planning on training - your training needs a plan!
Hot spots and intelligence 2
Hot spots and intelligence 2 In this second episode we look more broadly at the genesis of intelligence led policing, how it works and how compelling it is to draw parallels with our world of anti-financial crime.
Hot spots and intelligence
In this episode we report on a recent visit to the European Crime Analysis conference in Copenhagen and draw parallels between the work of law enforcement and those working in compliance. Links referred to in the episode…
Organised Crime - two's company but three's an OCG
We dive into the details of OCGs and how they use corporate networks to launder their ill-gotten gains - and the clues they leave behind. And, rather appropriately, we also introduce the world to our new sponsor: https:/…
A proliferation explanation conversation
In this episode we turn our attention to the thorny subject of proliferation financing and provide a basic explainer of what it's about and why it's important. The documents referred to in the episode can be accessed via…
Bias and noise – how they differ and why it matters
In this episode we take a (hopefully) user-friendly trip down the statistical road and explore some of the common pitfalls that can be encountered in preparing management information.
Investing in Testing - why assessment matters: Part 1
Does your assessment programme correlate to individual performance? And if not, why not? Part one of a journey on the road to cognition.
KYC - The Canary in the Coal Mine
In this episode we talk about using our (metaphorical) little yellow bird as a predictor of the overall effectiveness (or lack of it) of your anti-financial crime framework. Would your KYC fall off its perch at the first…
Synthetic data and real-world applications: The FCA call for input
The UK regulator, in common with most regulators around the world, is keen to understand the role that synthetic data might play, alongside Artificial Intelligence and Machine Learning. It has made a call for input which…
Selfies, Swipes and Security - authentication in the digital age
In this episode we look at all things digital and how it is changing the landscape of authentication whilst making KYC more dynamic.
Green flags and white lists
In this episode we want to move away from always being suspicious and look at the other side of the coin. Can we use green flags to help identify suspicious behaviour from a very different angle? And do we need to be cau…
Companies House Advanced Search
In this episode we enthusiastically review the new advanced search function recently launched on the Companies House website. We also make a heartfelt plea for other corporate registers to look and learn from the huge po…
Set the controls for the heart of the risk
In this episode we review the need for firms to review, and adjust as necessary, their financial crime control environment. We also talk about some of the triggers which might cause these adjustments and the actions whic…
Everything you ever wanted to know about remediation but were afraid to ask!
Remediation programmes are becoming an all too frequent feature of life for financial crime compliance departments, so we we’ve put together a summary of good practice, do’s and don’ts and other things to consider when e…
It's RAG week at The Dark Money Files
Sometimes you just have to go back to basics. And this week it's risk. Does low risk equal no risk? Is all risk equal? Should you ever do EDD on a low risk customer? We answer these questions and many more.
Financial Intelligence Units and the Egmont Group
In this episode we talk all things FIU along with the history and role of the Egmont Group. We discover the different flavours of FIU and how they work with the other elements of government and the law.
Everyone's a critic!
In this episode we look at the role of critical thinking in the world of Financial Crime Compliance. What it is, how it works and some examples of critical thinking in practice. And we conclude that it is one of the most…
Suspicious Activity Reports - Under the Spotlight
Following hard on the heels of the FinCEN files, the UK has just published its review of the SARs filed in 2019 which gives us the opportunity to look in detail at the headline figures and chat about SARs (both Money Lau…
Swedbank - the Clifford Chance report
Following the release of the Clifford Chance report into Swedbank's High Risk Non Resident portfolio (HRNR) in the Baltic States, we have recorded a special episode based on our initial review of the Executive Summary of…
The Financial Crime Guide
In this special episode to launch Season 4 we look at the newly revamped FCA - Financial Crime Guide and decide that it is an invaluable tool for financial crime professionals wherever in the world they might work. We al…
The Business Wide Risk Assessment
In this last episode of season 3 we turn our attention to conducting the business (or enterprise) wide risk assessment. Why and how figure prominently. We also look at the main elements of the soon to be introduced (as a…
Assessing Customer Risk #2 - Channel, Entity, Industry and Products
In this second part of assessing customer risk, we look at the impact of delivery channel, products, entity type and industry on the overall risk rating. We talk about the changes that new technology have had on verifica…
Assessing Customer Risk #1 - Geography
This week, after a brief review of the latest OCCRP stories (called #29leaks) we turn our attention to the thorny issue of customer risk assessments, starting with a focus on country or jurisdictional risk.
Risky Business
In this episode we complete our look at PEPs by going into Enhanced Due Diligence in a bit more detail before turning our attention to other high risk situations.
Panorama, Money Laundering, Whistleblowers and PEPS
In this episode we look back at a recent episode of the BBC1 news programme "Panorama" featuring drug money, gold bullion, billions of dollars of money laundering, poor treatment of whistle-blowers and a (very brief) app…
The highs and lows of correspondent banking
In this episode we look at the recent raid on Deutsche Bank in connection with the Danske Bank story, the role of correspondent banking in the story and the risks associated with it.
Extraordinary Danske developments and the need to report suspicions
We report on our involvement in recent leaks relating to Danske Bank and the potential criminal charges that can follow a failure to report. External reports commissioned and cancelled, suspicious activity detected but n…
Old banks and new technologies - oil and water?
In this episode we start a conversation about FinTech and RegTech (along with a few digressions and diversions along the way). In an abbreviation heavy episode, we talk about face and voice validation, iris scanning and …
Bitcoin, Blockchain and Cryptography - Time to look forward
This week, with some trepidation, we embark on an overview of some of the more esoteric elements of financial crime risk management. We attempt to explain the blockchain, cryptocurrencies like Bitcoin, and cryptography g…
Episode 9 - Danske Bank: The bond loop and the intermediaries
In 2013 Danske Bank executives started to examine,rather more critically, the lucrative bond sale business in Estonia. We look at the reporting and decision making process at the start of that journey and wonder whether,…
Special Episode 3 - The Swedbank/Forensic Risk Alliance Report Phase 1
Following the release of Phase 1 of the Forensic Risk Alliance report prepared for Swedbank, we take a detailed look at that it has uncovered and where we'd like Phase 2 to go.
Special Episode 2 - The Troika Laundromat
The second of our special episodes looking this time at the OCCRPs newly released data dubbed "The Troika Laundromat". Rather than spend 20 minutes criticising everyone involved we thought we'd spend some time contextual…
Episode 7 - The Suspicious Activity Report (Part 2)
In this jaw-dropping episode we look under the bonnet at the situation in Estonia just after Danske had bought Sampo. It highlights conflicting stories between what the Estonian regulator was saying to Danske (and in fac…
Episode 6 - The Suspicious Activity Report (Part 1)
In this episode we begin to look at the report, commissioned by Dankse Bank, which finally brought to light the full extent of what went wrong in Estonia. Part One explains the background to the report, the terms of refe…
Episode 4 - The Billion Dollar Hold
In this episode we look at a specific set of transactions within Danske Estonia - those emanating from accounts which are also located there. We do so because, of all the transactions that the bank handled, these are the…
Episode 3 - The Billion Dollar Shuffle
If you really want to understand why this was such a noteworthy failure of financial crime controls, this is the episode you really must listen to. We take the audience through the many different elements that constitute…
Read & explore
Binderr
How to ace your business-wide financial crime risk assessment
A practical approach to understanding what criminals might want from a business and assessing its controls.
Salv
Financial crime and the cost of compliance
A conversation with Alesia Ivankova on financial crime and the challenges facing compliance professionals.
LinkedIn
Identifying patterns in Companies House data
Finding meaningful patterns among newly formed companies.
Thirdfort
The three-part test for a file note that’ll survive an SRA review
Ray explains how to connect facts, supporting evidence and professional judgment in AML file notes, drawing on a Thirdfort webinar discussion.
Thirdfort
Enhanced due diligence after the 2026 MLR reforms: two mistakes firms are making
Drawing on Ray’s webinar discussion, Thirdfort explores two common responses to changing EDD requirements and the importance of assessing risk and supporting staff judgment.
Suggested subject matches; editorial review in progress.
THE BUSINESS SIDE
Training, speaking
and advisory work.
Looking for help with financial crime training, risk, compliance or an event? Our separate business website explains how Graham and Ray work with organisations and audiences.
Visit our business website