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Risky Convergences

October 28, 2024

New digital solutions in money laundering and underground banking have facilitated the expansion of the criminal business environment in Southeast Asia, integrate billions of criminal proceeds into the formal financial system and enabling the growth of new criminal organizations.

A PEP Talk

October 24, 2024

Politically exposed persons are individuals who, due to their positions of power, influence, or proximity to government, are susceptible to becoming involved in corruption, bribery, or other financial crimes. And because moving and hiding misappropriated assets often involves money laundering, financial institutions across the globe are tasked with the challenge of identifying and managing these risks.

A $3 Billion Mistake

October 22, 2024

TD Bank was recently slammed with a record $3 billion fine for failing to comply with AML laws. With $18 trillion in unmonitored transactions, the bank became a hotbed for criminal activity. What went wrong, and what can other financial institutions learn from this?

Beneficial Ownership: Who Owns What?

October 17, 2024

U.S. efforts to curb illicit finance are in full swing, as the requirement to reveal the beneficial owners of certain entities registered or operating in the United States came into effect this year. In this article, we explore key requirements, benefits, and deadlines as well as address some of the concerns organizations may have about the new regulation.

New BIS Export Compliance Guidance for Financial Institutions

October 15, 2024

The U.S. Bureau of Industry and Security recently published guidance for financial institutions on complying with strategic trade controls and discussing best practices, red flags, screening, and reporting. The latest guidance provides greater detail on due diligence and risk management to help financial institutions detect and deter emerging and evolving export controls evasion.

From Cash to Clicks – AML Challenges & Typologies for Digital Payments

October 2, 2024

Dive into the dynamic world of digital payments, where convenience meets innovation. Learn the challenges Payment Service Providers are navigating with smarter, technology-driven Anti-Money Laundering practices to ensure secure and efficient transactions.

Exploring the Balance of Innovation & Responsibility

September 24, 2024

In our recent webinar, industry leaders examined the intricacies of leveraging AI responsibly to enhance compliance strategies while safeguarding data privacy and ethics. Featuring a panel of industry experts including Shannon Barnes, Ajit Tharaken, and Catherine Woods, this blog post summarizes the key insights shared during the event.

The Risks of De-Risking

September 18, 2024

Compliance officers are guardians at the gate: protecting their organization and the global financial system from abuse while also ensuring that licit funds flow undisturbed. This is a delicate balance, as global regulations continue to grow in complexity, prompting some financial institutions to de-risk from high-risk clients. What are high-risk clients? Must a bank cease its relationships with these clients?

How has terrorism financing changed since 9/11?

September 12, 2024

While financial provisions enacted after the terrorist attacks of 9/11 have succeeded in addressing vulnerabilities in the global financial system, terrorist organizations have developed new methods of fundraising and moving assets, including digital assets and online platforms. In this article we examine how new technologies facilitate terrorism financing and the risks financial institutions should consider.

A Review of the Financial System Post 9/11

September 11, 2024

After the terrorist attacks on September 11, 2001, the private sector, especially financial institutions, began to play a vital part in protecting the U.S. and global financial systems. In this article we examine the changes to the financial system that resulted after 9/11 and discuss how the role of financial institutions has changed with respect to deterring and detecting the financing of terrorism.

AML Compliance for Small Businesses

September 4, 2024

Small businesses face the challenge of navigating the intricate landscape of anti-money laundering (AML) regulations. Despite the challenges posed by evolving global standards and limited resources, small businesses can use tailored strategies to fortify their compliance frameworks and thrive in a complex regulatory environment.

Collaboration Between Chinese Money Laundering Organizations & Drug Cartels

August 28, 2024

Global regulators are highlighting the growing threat of Chinese money laundering organizations that help transnational criminal organizations—particularly drug cartels—access and move assets through the global financial system. Global financial institutions must enhance their due diligence efforts, given the growing scope of the problem and the increasingly sophisticated methods used to launder drug proceeds.

Elevating Defenses

August 22, 2024

Dive into the cutting-edge strategies that financial institutions are implementing to combat the evolving threat of AI-driven fraud. From deploying advanced detection technologies to fostering robust networks of allies, learn how the financial sector is bolstering its defenses against sophisticated scams like deepfakes and biometric fraud.

Deepfakes and Dollars

August 20, 2024

While AI has the potential for transformative impact in the financial sector, it also introduces new challenges. From biometric mimicry to the alarming rise of deepfakes, this blog highlights emerging threats and challenges in countering AI-driven fraud.

Lessons from the Flight Deck

August 13, 2024

Automation and artificial intelligence, including machine learning, have the potential to provide significant benefits within financial services – however they must be implemented responsibly. In this article, we draw on the use of automation in other sectors such as aviation, review key global regulations, and examine regulatory enforcement actions, to identify best practices for responsible use of AI in compliance.

Adapting to Digital Assets Risks

August 8, 2024

In our recent webinar, "Mastering Compliance in Digital Assets through Multi-Tiered Defense Strategies," industry leaders examined the intricacies of digital asset compliance. Featuring a panel of industry experts including Andrew Rosenberg, Elizabeth Severinovskaya, and Catherine Woods, this blog post summarizes the key insights shared during the event.

Working Together to Fight Transnational Financial Crime

July 30, 2024

The transnational nature of criminal networks, cross-border financial flows, and sometimes the international nature of crimes themselves, mean a unified response between the public, private sector, and “third sector” is critical. This article uses the example of human trafficking to identify the capabilities of each sector and how they can achieve the greatest effect by working together.

The Convergence of Sanctions & AML

July 24, 2024

The convergence of sanctions and anti-money laundering efforts has significantly accelerated since Russia’s full-scale invasion of Ukraine in February 2022. FINTRAC in June 2024 released a special bulletin focusing on financial activity associated with suspected sanctions evasion. The report highlighted shared methodologies and insights to help compliance teams collaborate on best practices.

Three Lines of Defense: Case Study

July 18, 2024

The “three lines of defense” model is a widely recognized approach for effectively managing financial crime and regulatory risk. But how does it work in practice? This article explores how the three lines of defense applies using client due diligence as a real-life case study.

Targeting Russia’s IT Dependencies

July 16, 2024

Delve into the recent determination issued by OFAC, which imposes significant additional restrictions on the provision to Russia of IT consultancy and design services as well as IT support and cloud-based services of enterprise management and design and manufacturing software. Multinational tech corporations, financial institutions, and other companies still operating in Russia will likely require licenses to continue operating there.

Crypto Under the Microscope

July 11, 2024

In the fast-evolving digital assets market, compliance is not just a regulatory requirement—it's a strategic imperative. From Binance's multi-billion-dollar settlement to the dramatic collapse of FTX, recent enforcement actions have sent shockwaves through the industry, underscoring the critical need for a robust compliance system.

Three Lines of Defense

July 9, 2024

The “three lines of defense” is a well-established model for implementing an organizational structure to effectively manage financial crime risk and regulatory compliance. Explore the three lines of defense, their responsibilities and the advantages of the three line model in this article.

Understanding and Addressing Fraud and Corruption Risks

July 2, 2024

In our recent webinar, industry experts delved into the crucial topic of fraud and corruption risks. From seasoned professionals to anti-corruption activists, the webinar featured a panel of distinguished speakers: Steve Burgess, Nikki Kenyon, Chris Williams, and James Wasserstrom. This blog post aims to summarize the key points discussed during the session, equipping readers with the knowledge necessary to navigate these risks effectively.

Embracing Emerging Technologies through Capability Development

June 27, 2024

Risk is perceived to be higher when a subject area is unfamiliar, which is particularly likely for emerging technologies and products. One solution is to develop the capability of staff through training and experience, where Chief Compliance Officers can utilize partners to support upskilling and augment internal capability where required. Digital assets provide a good case study: detailed knowledge within financial institution compliance and business teams to manage risks while enabling business growth.

Corruption in Construction

June 21, 2024

Corruption in the construction sector can include everything from fraud, to extortion, embezzlement, and other abuses. Corruption doesn’t just undermine good governance; it endangers lives and threatens the reputation of any financial institution involved in construction projects that are rife with fraud and abuse. How can government organizations and financial institutions mitigate corruption risks when funding or supporting infrastructure projects? How can they detect suspicious transactions?

OFAC’s Compliance Guidance in Action

June 18, 2024

The Treasury Department’s Office of Foreign Assets Control (OFAC) five years ago published its Framework for OFAC Compliance Commitments. This guidance remains the most comprehensive articulation of OFAC’s compliance expectations to date. Although it notably stopped short of mandating a sanctions compliance program (SCP), recent enforcement actions demonstrate the implications of not having an SCP in place.

Corruption Kills

June 13, 2024

Construction projects are especially vulnerable to corruption because of their complexity, high price tags, and the number of intermediaries and other parties involved. Corruption in the construction sector does not merely result in financial losses, environmental destruction, and inequality, but it can also result in loss of life.

FinCEN Issues Warning to Financial Institutions

June 11, 2024

Iran continues to explore techniques that allow it to move funds to terrorist proxy groups in its efforts to destabilize the Middle East and project power by supporting the global operations of dangerous militias, proliferation of weapons, and malicious cyber activities. Financial institutions must be increasingly vigilant in detecting illicit transactions linked to Iran-backed terrorist organizations. Regulators have providing guidance, including red flags, and highlighting methodologies used by terrorist groups to raise funds.

Tech vs. Corruption

June 6, 2024

As corruption continues to pose significant challenges across various sectors, including government agencies, traditional banking institutions, and designated non-financial businesses and professionals (DNFBPs), innovative technological solutions are proving to be essential in combating these issues. This article highlights how blockchain, AI, and data analytics are revolutionizing the fight against corruption.

Types of Sanctions – A Vast and Varying Landscape

June 4, 2024

In the United States, most sanctions programs combine multiple types of designations that vary across multiple dimensions. U.S. designations are constantly changing, and more individuals, entities, vessels, and aircraft are being added to OFAC’s sanctions list. Explore the five primary types of sanctions in our latest article.

Upholding Integrity — Obligations in Combating Corruption and Bribery

May 29, 2024

Bribery and corruption represent a critical nexus where ethics, governance, and societal values intersect. These issues have long been a stain on both public and private sectors, creating distrust and distorting fair competition. International bodies and conventions typically define public sector corruption as the abuse of public office or a position of public trust for private gain. Explore a recent case study and how organizations can protect against corruption.

Russian Use of Crypto for Sanctions Evasion on the Rise

May 21, 2024

Experts agree there isn't enough liquidity in the virtual assets space to enable largescale sanctions evasion by Moscow, but sanctioned individuals and entities have used virtual currencies—most notably Tether—to access the global financial system and pay for restricted goods and technologies. Explore recent designations, how cryptocurrencies and other virtual assets are being leveraged to facilitate evasion as well as risk mitigation strategies for financial institutions in our latest article.

AI in Crypto Security: Navigating the Dual Edges of Innovation and Vulnerability

May 14, 2024

As cryptocurrencies gain mainstream acceptance, they also become a new frontier for financial crimes, including money laundering, fraud, and the financing of terrorism. Amidst this burgeoning digital economy, AI emerges as both a beacon of hope to help prevent crimes and a potential threat, giving illicit actors additional resources to move proceeds of crime. The dual nature of AI in combating or facilitating crypto-related financial crimes presents a complex puzzle: Is AI a harbinger of risk or the ultimate solution to mitigate it in this digital age of ambiguity?

Fake News vs. Real News – The Importance of Media in Due Diligence

May 6, 2024

We exist in an age when mass media outlets are criticized for bias and manipulation, and when foreign disinformation efforts further erode trust in traditional journalism. Confidence in media reports not just as a compliance tool, but also as reliable news sources is likely at near record lows as well. However, adverse media reports are a critical compliance tool that can serve as a springboard for more extensive due diligence research and can help identify potential indicators of sanctions evasion and other financial crimes.

Digital Assets in the Crosshairs

May 1, 2024

As the digital economy burgeons, cryptocurrencies, tokens, and NFTs have shifted from niche investments to central elements in global finance. Yet, this rapid growth brings complex challenges, especially in the realm of financial security and regulatory compliance. Explore how these assets are increasingly being used to fund activities that threaten global security.

Counterproliferation Finance Detection and Deterrence – What Can Financial Institutions Do?

April 23, 2024

The U.S. Treasury recently identified proliferation networks operating on behalf of Russia, North Korea, China, Iran, Syria, and Pakistan as threats to U.S. national security. These networks exploited the U.S. financial system to finance the proliferation of weapons of mass destruction (WMD), including financing to procure WMD components and raising revenues to support efforts by these state actors to advance their WMD activities.

2024 National Proliferation Financing Risk Assessment

April 19, 2024

The U.S. Department of the Treasury published the 2024 National Proliferation Financing Risk Assessment in February 2024 providing an in-depth analysis of the threats and vulnerabilities related to proliferation financing (PF) and highlighting key countries and non-state actors working to gain access to weapons of mass destruction (WMDs) and their components and to conventional restricted weapons and technologies.

Liberating Limits: OFAC Licenses

April 8, 2024

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) safeguards national security and helps advance U.S. foreign policy objectives by administering the U.S. sanctions regime. OFAC’s general and specific licenses serve as key mechanisms for authorizing and regulating certain transactions that would otherwise be prohibited under sanctions programs. The exceptions provided by licenses help businesses and individuals navigate international transactions without violating U.S. sanctions policies.

Golden Visas & Global Graft – How Criminal Actors Exploit Citizenship by Investment Programs

April 3, 2024

While special naturalization programs offered in certain jurisdictions to foreign investors intend to attract foreign direct investment and economic and infrastructure development, these programs can be abused by criminals who seek to launder and conceal proceeds of crime or commit new offences, including financial crimes.

Crypto Jargon Defined: Bridging the Gap Between Complexity and Comprehension

March 28, 2024

From mixers and tumblers to hot and cold wallets, the crypto space is laden with complex jargon. Explore our post in which we simplify the language of the digital economy. Ideal for enthusiasts at any level—from curious beginners to those seeking deeper insights—this guide illuminates the path to mastering the nuances of digital, virtual, and crypto assets.

Stuck and Seized – Consequences of Forced Labor

March 26, 2024

Global economies are more interconnected than ever, and human rights abuses can have a profound impact on supply chains and disrupt the flow of goods. Recent deliveries of certain luxury vehicles, such as Porsches, Audis, and Bentleys have been delayed because a small component that links those vehicles with computer networks was produced by a Chinese company linked to forced labor and surveillance of Uyghur populations in China.

Russia Sanctions Evasion Case Study: Viktor Labin

March 18, 2024

When conducting customer due diligence and enhanced due diligence, simple screening for names that may be on sanctions lists is no longer sufficient given the increasing complexity of Russia’s sanctions evasion efforts and the volatile regulatory environment because of Moscow’s aggression against Ukraine. Extra research is necessary to ensure compliance with sanctions laws and adherence with your company’s own risk policies. This research, however, can be complex, and structured analytic techniques and tools are necessary for effective due diligence.

Are Casinos Havens for Money Laundering?

March 12, 2024

A recent UN Office on Drugs and Crime (UNODC) report has found that casinos, junkets, and cryptocurrencies are exacerbating transnational organized criminal activity in East and Southeast Asia as part of the region’s underground banking and money laundering infrastructure. Although the use of casinos to launder money is not new, the proliferation of online gambling since the COVID 19 pandemic has aggravated the existing problem and has given rise to underregulated online gambling venues as more gamblers began playing from home.

Binging Griselda? Let’s Talk Drug Trafficking Sanctions

March 7, 2024

Netflix’s new series Griselda tells the story of Griselda Blanco. Known as the “Godmother of Cocaine,” Blanco trafficked cocaine from Colombia to Miami from the 1970s to the early 2000s. Despite her criminal activities, Blanco managed to evade law enforcement for many years. There were no sanctions against Blanco at the time, since the Kingpin Act, a U.S. law aimed at combating international drug trafficking and organized crime, was enacted in 1999 after Blanco’s sentencing.

Risky Russia – Government Agencies Warn Businesses of Possible Trouble

March 5, 2024

The US Departments of State, Treasury, Commerce, and Labor in late February issued a business advisory warning firms and financial institutions about the serious legal, financial, and reputational risks of doing business in Russia. According to the State Department’s assessment, Russia’s kleptocratic environment undermines fair competition and the rule of law, exposing businesses to the risk of extortion, appropriation of assets, and US law enforcement action.

Thanks to Russia, Cross-Border Sanctions Collaboration at All-Time High

February 28, 2024

Russia's unprovoked invasion and continued aggression in Ukraine has led to an unprecedented level of collaboration by sanctions stakeholders across jurisdictions, agencies, and sectors. IFI is publishing a series of blogs to highlight this increased collaboration. In this first blog, we take a look at cooperation across borders and most notably by the REPO Task Force and Price Cap Coalition.

Beyond The Hype: The True Role of Virtual Assets in Russia Sanctions Evasion

February 27, 2024

With the onset of stringent sanctions against Russia in 2022, US officials and financial analysts began to speculate about the potential for cryptocurrencies to serve as a means for evasion. But can virtual assets enables a nation's efforts to evade sanctions?

Ukraine’s War on Two Fronts – Fighting Corruption Amidst Russia’s Continued Attacks

February 20, 2024

As the second anniversary of Russia’s full-scale war of aggression in Ukraine approaches, winning on the battlefield remains the top mission objective for the Armed Forces of Ukraine, the Ukrainian people, and Ukraine’s international partners. While the full-scale invasion began two years ago, addressing systemic governmental and economic corruption has been an enduring battle for Ukraine since it gained its independence from the Soviet Union in 1991.

Pig Butchering on the Rise: When Romance Goes Wrong

February 14, 2024

What is pig butchering and how does it work? Read on to explore the global regulatory response to this rising scam, identify scam tactics and key mitigation strategies.

Exhausting Russian Resources by Sanctioning Western Software

February 8, 2024

Despite the Kremlin's attempts to reduce reliance on Western software for crucial systems, this transition is advancing slowly, presenting significant opportunities to hinder Russia's military effectiveness and economic activities. Read on for more information on the current role of Western technology and guidance for governments and companies formulating sanctions proposals.

Evading Export Controls – Russia’s Key to Success

February 6, 2024

Russia has used third-party intermediaries to evade sanctions and export controls for years and has disguised the involvement of SDNs or sanctioned entities in transactions to obscure the true identities of end users. This activity has increased since Russia’s invasion of Ukraine in 2022 due to Russia’s need for military equipment.

Bad News for Corruption in 2023, Along with Some Bright Spots

February 2, 2024

Transparency International released its annual Corruption Perceptions Index, ranking 180 countries and territories by their perceived levels of public-sector corruption. Explore the highlights within.

Human Trafficking

January 30, 2024

January is National Human Trafficking Prevention Month, and IRS-Criminal Investigations (CI) is partnering with other government agencies to highlight indicators and federal initiatives to combat this crime.

Bitcoin Breakthrough – Navigating the New Era of SEC-Approved Spot Bitcoin ETPs

January 26, 2024

The US Securities and Exchange Commission's (SEC) landmark approval of 11 Spot Bitcoin Exchange-Traded Products (ETPs) from several leading financial firms, including BlackRock, Fidelity, and Grayscale Investments, this month marks a significant shift in the regulatory landscape for virtual assets.

Real Estate in 2024 – Anticipating a Crackdown on Corruption & Fraud

January 24, 2024

Real estate in the United States has long been a popular channel for corrupt actors seeking to launder illicitly obtained funds. As part of the Biden administration’s 2021 Strategy on Countering Corruption, a long-awaited proposed rule from the Treasury Department that is slated to take effect in early 2024 will seek to address that glaring loophole in US anti-money laundering (AML) regulations.

How to Avoid Becoming an Unwitting Facilitator of Russian Sanctions Evasion

January 17, 2024

What steps can organizations take to avoid becoming unwitting suppliers of critical components and tools for the Russian military?

The Importance of a Sanctions Compliance Program – Top 5 Mitigating Measures Highlighted by OFAC in 2023

January 11, 2024

OFAC in 2023 reached settlements with 17 companies, collecting more than $1.5 billion in penalties. Mitigating factors can help reduce the severity of penalties imposed by OFAC for sanctions violations and often involve significant remedial measures and enhancements to a company’s sanctions compliance program.

A Pivotal Year for Virtual Assets – 2023 Highlights

January 8, 2024

2023 was a year of significant upheavals in the world of virtual assets, highlighting glaring vulnerabilities and the dire need for regulatory interventions. From major financial losses caused by security breaches to high-profile legal battles and settlements, 2023 was chock full of developments that almost certainly demonstrate the resilience and endurance of virtual currencies.

A Timeline of US, EU, and UK Sanctions on Russia in 2023

January 3, 2024

The United States, United Kingdom, and European Union, among others, have increased their focus on enforcement, updated sanctions lists and export controls to limit Russia’s access to sensitive technologies, and taken steps to punish illicit actors assisting Russia. Explore a list of the various sanctions imposed by the United states, EU, and UK in 2023.

Biden Signs Executive Order Targeting Foreign Banks Supporting Russia

December 29, 2023

US President Joe Biden on December 22, 2023, signed an executive order to authorize the US Treasury Department’s Office of Foreign Assets Control (OFAC) to designate foreign financial institutions that help Russia’s defense industry, as Moscow’s war against Ukraine approaches its two-year anniversary.

What Financial Institutions Can Learn from the Binance Settlement

December 7, 2023

Explore lessons learned from the recent Binance settlement including risk mitigation strategies for banks and other financial institutions.

Binance Settles with Regulators

November 21, 2023

Binance, the world’s largest cryptocurrency exchange, on November 21st pleaded guilty and agreed to pay more than $4.3 billion to resolve the US Justice Department’s investigation into its violations of the Bank..

Cyber-Enabled Fraud

November 14, 2023

Cyber-enabled fraud (CEF) is growing, especially with increasing digitalization across the globe. Technological advances have enabled cyber criminals to develop and increase the scale, scope, and speed of their illicit activities.

Terrorist Use of Crowdfunding

November 8, 2023

The nature of crowdfunding, the use of new technologies, and the possible anonymity afforded by crowdfunding platforms can make them attractive as relatively quick and simply means to obtain donations from across the world.

Partial Sanctions Relief for Venezuela

October 31, 2023

On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued six general licenses authorizing categories of transactions that were previously prohibited under the U.S. sanctions program against Venezuela.

Best Practices for the Maritime Oil Industry to Detect Restricted Trade in Russian Oil

October 16, 2023

Price Cap Coalition partners have published an Advisory following reports that Russia has been evading the $60 per barrel price cap that was imposed by the Coalition last year. The Advisory provides some best practices and recommendations to the maritime oil industry to help stakeholders reduce their exposure to risks of Russian oil cap evasion by detecting restricted trade in Russian oil.

MiCAR Defined – The EU’s Blueprint for Crypto Regulation

July 10, 2023

The Markets in Crypto-Assets Regulation (MiCAR) went into effect on June 29, 2023, and will be fully applied by December 30, 2024.

Domestic Terrorism – Understanding the Threat and How Banks Can Counter It

January 3, 2023

Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical ideologies. In response to these troubling developments, our government has stepped up law enforcement, intelligence attention, and resources to combat these threats.

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