Four recommendations to improve operational compliance – lessons from downunder
June 29, 2021
For this Trend Letter I’ve found 2 articles with a link to Australia. The first is about the never-ending ingenuity of money launderers and the phenomenon of cuckoo smurfing…
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CDD analysts: they ‘look’ but what does it take to make them ‘see’?
June 29, 2021
Edwin Hers – June 2021 Authorities are showing their teeth. Multiple financial institutions have settled with the authorities over the last couple of years related to inadequacies in their KYC…
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MONEYVAL 2020 Annual Report
June 29, 2021
With its 36 member-states and territories MONEYVAL is the largest of eight FATF-style regional bodies. It is the monitoring body of the Council of Europe entrusted with the task of assessing…
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2021 Q1 Trend Letter
March 25, 2021
Following the 2008 financial crisis regulators and the industry resolved to improve their control of the OTC derivatives markets and a raft of regulations ensued. For Europe EMIR was adopted and in…
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The AML system is broken
March 24, 2021
Conventional wisdom dictates that an investment is justified by the return it provides. This clearly is not a driver for the $180B banks spent in 2020* fighting money laundering because, let’s face…
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Of course they knew
March 24, 2021
Reading this summary https://www.riskscreen.com/kyc360/news/newly-obtained-audit-report-details-how-shady-clients-from-around-the-world-moved-billions-through-estonia/ of what happened at Danske Bank…
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EMIR, where do we go from here?
March 24, 2021
EMIR is the EU regulation to reduce the systemic risk of OTC derivatives by setting guidelines for reporting to the regulators, making clearing mandatory for a large proportion of the trades and…
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2020 Q4 Trend Letter
December 21, 2020
What a remarkable year 2020 was! As it draws to a close we keenly look forward to what 2021 may bring. In this last Trend Letter of 2020 we focus on several subjects that we think will matter to the…
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Crypto and traditional financial institutions
December 21, 2020
In a way I’m probably like many professionals coming from a traditional banking environment and have a bit of a blind spot for anything like crypto or distributed ledger technology, bitcoin and token…
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Data Quality in KYC/AML
December 21, 2020
Ever since in May 2018 the ECB published the “Report on the Thematic Review on effective risk data aggregation and risk reporting” data quality has improved – not only in Europe- as one of the big…
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2020 Q3 Trend Letter
September 28, 2020
As the world focuses on controlling the COVID-19 pandemic, the plague of financial crime continues to thrive. This quarter's Trend Letter focuses on the global business of cybercrime (estimated…
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Living in a New Reality, a Perfect Storm with Changing Dynamics
September 23, 2020
By Victor van der Kwast These days we live in a perfect storm, with global warming, COVID-19, geopolitical shifts, power struggles, election campaigns, the next steps (or not) in Brexit and a new way…
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