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
Regulation & enforcement
What the rules say—and what happens when they are broken.
The questions behind the subject
Read the rules alongside the cases. These conversations follow legislation, supervisory findings and enforcement, asking what they mean for the way financial crime is prevented and detected.
- What behaviour did an enforcement case identify?
- What changes when new powers or obligations are introduced?
- How can firms turn a regulatory finding into a practical improvement?
SUGGESTED LISTENING SEQUENCE
Read the dates alongside the discussions: rules and investigations develop over time.
All episodes in this collection
Happy birthday OFSI
Ten years after the creation of the Office of Financial Sanctions Implementation, we look at how the UK sanctions regime has evolved—from early uncertainty to strict liability enforcement, sanctions list complexity, and …
A fine fanfare - Coinbase and JP Morgan SE
We examine two recent final notices issued by two different regulators relating to two quite different enterprises and find a surprising amount of commonality in their thinking.
Policing the corporate landscape - the role of The Insolvency Service
The UK Insolvency Service does a lot more than just oversee insolvencies and, in a recently published five year strategy document, they outlined some ambitious future goals which we thought were well worth a conversation…
The highs (and lows) of PEP classifications
The FCA recently published new guidance specifically in relation to UK PEPs which we decided needed a closer look. So we did!
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…
Unheard voices - fine outcomes
In this episode we look at some of the links between three recent enforcement actions. We try to avoid the knee jerk reactions, and think a bit deeper about them.
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…
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…
It's over to EU
It’s over to EU After a succession of episodes looking at the UK financial crime landscape, we shift our focus over the channel to Europe and the proposed changes to EU AML legislation.
Show me the money!
In this episode we bring you an update about regulatory expectations in respect of cash deposits. Along with a brief history of the UK’s Post Office dating back to the 17th century and the somewhat surprising news that i…
VATs the problem?
In the first episode of season 10, we turn our attention to an extraordinary story about online retail sales, China, VAT and HMRC. Despite all the apparent jargon, it is just an everyday tale of 11,000 companies all sudd…
Dr Blake’s casebook – a roundup of stories you may have missed
In this episode we work through three of the smaller regulatory actions from last year which nevertheless contain nuggets of gold, successfully panned by Ray.
Can we have the Bill please?
In something of a departure from our normal content, we review the passage of the Economic Crime and Corporate Reform Bill through the UK parliamentary system and use the opportunity to explain in more detail just how th…
AOB – recent publications and guidance
It’s been a little while so we thought we’d do a bit of a catch up on some recent publications from Wolfsberg, the FATF and the Finnish FSA.
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…
NatWest Bank and HSBC: The King, his cleaner and the thirsty aspidistra
We bring this trilogy of episodes around transaction monitoring failures to an end with a final review of the NatWest case and a comparison with the recent fine levied against HSBC. What’s that got to do with a King, his…
NatWest Bank and the Bradford Laundromat - part 1
In this episode we bring you part one of a deep dive into the criminal prosecution of NatWest through the lens of the Statement of Facts which accompanied the guilty verdict. No matter where you are in the world, given t…
Regulators, statistics and benchmarking
In this episode we look at how the FCA’s REP-CRIM report can assist firms in assessing the effectiveness of their AML controls through both trend analysis and benchmarking against their peers. And we explain how trend an…
The FCA's Dear CEO AML Letter
We interrupt our series on Alternative Laundries to review the recent FCA Dear CEO AML letter which, whilst aimed squarely at UK financial institutions, will have relevance across the world, especially where those global…
HMRC, TCSPs and other impossible scrabble hands
In this episode we review the recent guidance issued by the UKs tax regulator (HMRC) for the benefit of Trust and Corporate Services providers. Amongst other things, it provides a very clear and articulate statement of s…
A fine day in London and Stockholm (part 2)
In this second part of our review of recent fines against SEB in Sweden and Commerzbank in the UK we dive into the detail of the Commerzbank Final Notice which reveals one or two surprises!
A fine day in London and Stockholm
In this episode we begin our review of the Commerzbank fine by the FCA and give a brief overview of the SEB fine by the Swedish FSA. What can we learn from these events? Have a listen to find out!
A fine day for a podcast
In this episode we look at the effectiveness of AML control frameworks, what we might mean by effectiveness, the use of fines and the onset of compassion fatigue, We also announce the forthcoming Dark Money Conference ab…
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…
It's time for a PEP talk!
In this episode we talk all things PEP. We cover how to define one, what constitutes a relative or close associate, what is the difference between source of wealth and source of funds and the thorny issue of PEP retireme…
Swedbank shines a light but FATF prefers privacy
This week we look at two separate issues (but there are similarities). First up, Swedbank published its 3rd quarter results this week and included an update on their ongoing investigations into the alleged use of their b…
The feeling's mutual - The Financial Action Task Force and the Mutual Evaluation Report
This week, in honour of the first 2019 Plenary meeting of the FATF we look at the birth of the organisation in Paris in 1989 and a pillar of its existence - The Mutual Evaluation Report.
The Deutsche Bank Story, Part Three: What the FCA found
In this episode we complete our review of Deutsche Bank's inspection by the FCA which led to them being fined £163m (and $425m by the Department of Financial Services - New York). W explain in some detail all of the area…
The Deutsche Bank Story, Part Two - The FCA comes to visit
In this second part of our in-depth review of the recent travails at Deutsche Bank we talk about the background to the Systematic AML Programme (SAMLP) visit by the FCA, the LIBOR fine which preceded it (including the £1…
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,…
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…
Special Episode 1 - The Ousting of Danske and the Arrival of Swedbank
Following an extraordinary week of developments which saw the removal of Danske from Estonia, its voluntary departure from Latvia, Lithuania and Russia, the launching of an investigation of both Danish and Estonian regul…
Read & explore
The Banker
Companies House clean-up hits fraudsters hard
Graham’s commentary on Companies House and the changing corporate landscape.
Publisher subscription requiredHouse of Commons
Economic crime: evidence to Parliament
Ray gives evidence on economic crime, Companies House and the need for effective prevention.
Official transcriptThirdfort
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.
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