Entries by Yanni Chen

Three Lines of Defense: Case Study

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

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

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

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.

Embracing Emerging Technologies through Capability Development

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

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

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

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

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.