Book Review – The Global Threat Assessment – From Leading Financial Crime Fighters

No-one can dispute the existence of large criminal markets generating huge profits for those involved, but which Criminal markets are the largest, which are the fastest growing and which markets are emerging?

Which Countries generate the most in Criminal proceeds and which Countries are likeliest to launder most, from domestic and foreign financial crime proceeds?

Which money laundering methods are the most popular, and which groups benefit the most? 

In this Book, estimates are provided to answer all of these questions and more.

To read the Preface to the GTA by sir Iain Lobban, former Head of the UK’s GCHQ click HERE.

To Download / Read a copy of the GTA click HERE.

To watch the video summary of the main findings of the GTA click HERE.

Leading Financial Crime Fighters have their say on the Global Threat Assessment

Book Reviews:

– by Hans Peter Bauer, Founder and Senior Adviser to the Wolfsberg Group – “Finally, here it is. From now on we shall have a quantitative basis on how to go forward in the fight against financial crime, the financing of terrorism and the implementation of sanctions, which has been missing for so long. To my knowledge John Cusack’s new book, for the first time, presents a global overview of the volume of crimes committed, exposed countries and money laundering methods, with impressive and sometimes surprising results. Whatever progress we want to make on improving the effectiveness in the fight against financial crime we shall need a quantitative basis to set the priorities in all three categories and to assess objectively the performance of all the measures taken. For this purpose John Cusack’s latest publication offers indispensable support which should be updated and deepened on a regular basis. In addition, the book contains valuable considerations and in particular recommendations on how to address and progress these issues going forward. The stage is set. In all aspects, the book profits immensely from John’s vast professional experience and his network of international experts on the subject.”

– by Chris Brannigan, CEO of Caspian, “John Cusack’s Global Threat Assessment, provides a unique picture of financial crime threats, across crimes, countries, methods and groups, revealing the true size and scale of the problem, like never before. The Global Threat Assessment also provides answers on how to fight back and how to improve overall effectiveness. Caspian supports increased effectiveness in FI financial crime compliance programmes through its leading solution, “Transaction Investigator” using advanced technologies to support financial crime investigations, which only goes to endorse a number of key observations and recommendations, including embracing innovation, regtech, which are already proving it’s possible to make a bigger difference.

– by Rob Campbell, Programme Director of the United for Wildlife Transport & Financial Taskforce’s, for the Royal Foundations as. “The collection of detailed information here is unparalleled, a consolidated report covering all forms of financial crime, and refreshingly one of the first reports to include the growing risks of wildlife trafficking. John has become a real ally for the United for Wildlife Taskforce’s with his depth of knowledge on the financial flows of illicit trade and money laundering, helping us understand the similarities with other financial crimes, many of which are outlined in this report.”

– by Ruth Dearnley, CEO of Stop the Traffik, “John Cusack is an explorer in a world of crime that creates revenue from many sources and his interaction with anti human trafficking is a welcome one. Particularly when the world of anti trafficking is populated by such a wide variety of NGO agendas. And the research base for human trafficking is significantly shorter in terms of time than many other threat areas. In 2007 HT was not on any threat assessment anywhere. We are still learning. Stop the Traffik believes firmly that HT will only decrease if we are able to share the richest picture of how and where it is manifest in a way that works for all actors, whether that Law Enforcement and Justice process; Financial Services, Banking or Business; Multi Lateral entities and NGOs in the widest sense. And it is a 2 way revolution, with all actors sharing what they know in a non competitive, safe space. Intelligence for action doesn’t just mean for investigation in the traditional policing sense. It’s how every sector reviews its exposure and activity and HT proofs it No demand for the product and services of trafficked / exploited people equates to zero income for traffickers. It is said that 89 million people have had an experience of HT / exploitation in the last 5 years and this tells all of us that there is a significant churn in this business. We need to collaborate in ways that undermine this potential for new recruits.  And it is just about money, access to money and the ability to use and move it. The challenge is to build and digitise the financial typologies of trafficking and to encourage traffickers to expect to be denied these abilities.  The world of FSOs has a pivotal role to play in fundamentally undermining the business that is Human Trafficking and Johns work and this publication are really helpful guide.” 

– by Tom Cardamone, CEO, Global Financial Integrity, “At a time when financial crime is generating more illicit funds than any other time in history, this judicious report presents a comprehensive picture of the size, composition and evolution of financial crime throughout the world. The contents of this report are simply stunning; the world must do more to curb financial crime. This study illuminates the pervasive extent of financial crime throughout the world, and offers cogent analysis and solutions for a way forward.

– by William J Fox, Co-Chair of the Wolfsberg Group and Financial Crimes Executive at Bank of America,  “I have had the pleasure of intersecting with John Cusack from time to time for the past 16 years.  Most recently I have had the honor as serving with him as co-chair of the Wolfsberg Group.  Over the years, I have learned that John’s passion for the fight against financial crimes is unmatched.  He is insightful, creative and experienced as well as indefatigable.  He brings all of these skills to bear in full display in his Financial Crimes News: A Global Threat Assessment.  In a tactical sense, John has developed a very useful assessment that will prove highly useful to financial crimes professionals – be they in the private or public sector.  He covers the landscape of criminal markets, exposed jurisdictions, money laundering methods and criminal groups all with facts, figures and incisive analysis.  This assessment is a highly valuableguide and framework of how professionals should think about financial crime. But perhaps more importantly, John’s assessment has a strategic bent with insightful recommendations that would make both national and financial institution financial crimes programs more effective.  I have walked part of this journey with John at the Wolfsberg Group as he was developing his thinking.  I believe he is on the right track and that this assessment provides an important voice for much needed reform of the financial crimes regime.

– by Khoo Boon Hui, formerly President of Interpol, senior Deputy Secretary in Singapore’s Ministry of Home Affairs and commissioner of the Singapore Police Force – “ All too often in the fight against financial crime, we base actions on perceived threats and on public concerns, oftentimes amplified by legitimate media reporting. But there still remain serious gaps in our understanding and awareness. John Cusack’s Global Threat Assessment shows how these gaps are being exploited and with evidence collated, aggregated and analysed, he demonstrates how we need to raise our game in both targeting and achieving greater success in the fight against financial crime. More than this though, John Cusack’s Global Threat Assessment provides serious food for thought for all of us, as it reveals what can already be done with publicly available sources. We need to consider what more could be achieved if we match this exercise with so far restricted private information from around the world. It is clear that to succeed we have to share more information and to find ways for all stakeholders, public and private, local and international to work better together.”

– by Jason Holt, EMEA Lead Exiger, and Former FCC head in the U.K. and EMEA and BNP Paribas, Bank of America and JPMorgan, “This book is an Invaluable roadmap to the financial crime challenges our world faces today. Supported by a wealth of well sourced data, this book navigates the reader through the significant financial crime threats we face today, as well as the opportunities we have to resolve these and the impact if we fail to do so. The only useful fact missing here, is that which measures the positive impact this author has already had on reducing financial crime globally. This is a must read, not only for financial crime professionals but anyone who cares about our planet or society.”

– by David Howes, Global Co Head Financial Crime Compliance, Standard Chartered Bank, “As always, John has added to the debate on tackling financial crime through his research better to understand its scale and scope.  There is a lot here to digest and to provoke debate about the most effective way to respond, which must be in partnership across the public and private sectors if we are going to realise the full potential of using financial intelligence to tackle criminal and terrorist threats.”

– by Tom Keatinge, Director, Centre for Crime & Security Studies at the Royal United Services Institute, “The response to financial crime is predicated, in part, on ‘known unknowns’, but aggregating what empirical data we do have is an important step in arraying our limited resources against the threat.  This new report provides a valuable base on which further research and both public and private sector intervention can be based.”

– By Gottfried Liebrandt, CEO of SWIFT until 2019, “This work provides a clear and quantified overview of financial crime in terms of type of activities, geographies and tools and techniques used to launder the financial proceeds. By highlighting the key areas of risk it will allow the financial industry to focus their Financial Crime Compliance efforts, thus greatly increasing both effectiveness and efficiency.  It is a must read for Financial Crime Compliance professionals.”

– by Iain Lobban, Head UK GCHQ until 2014 as “I have worked for over four years with John Cusack, the principal author of this Report. Those who know him will attest to his experience and expertise, his authority and his restless quest to make a difference. It is hard to escape his view that not enough is being done, that insufficient focus is being brought to bear on our strategic and operational counters to this global, ever morphing phenomenon of financial crime.” – see more in Preface to GTA.

– by Vishal Marria, CEO of Quantexa, As a leading solution provider disrupting the way FIs tackle financial crime, John Cusack’s Global Threat Assessment resonates completely. It not only clearly articulates the nature of the threat, but also the requirements needed to create tailored solutions. Quantexa is already demonstrating increased effectiveness for its FI clients through the use of AI and big data analytics and supports greater information sharing as recommended in this this authoritative publication.”

– by Michael Matossian, EVP, Global Head of Group Regulatory Compliance at Arab Bank and Founder and Deputy Chair FCC MENA Group,  “Financial crime threats continue to expand and diversify cutting across borders, sectors, and markets. Addressing this global problem requires looking through the macro lens for better unveiling the changing faces of financial crime. That is why I consider this report “FCN: Global Threat Assessment” authored by John Cusack, an important resource for Heads of Financial Crime and Money Laundering Reporting Officers. Entrusted every day with steering efforts, resources, and capabilities in the right direction and in alignment with evolving threats and current waves, the report offers compliance practitioners an all-encompassing overview of the financial crime current environment across different markets, countries, methods and groups with each risk area tackled in great detail. Some of these are emerging themes, whilst others are more traditional areas where criminals continue to tap new ways to bypass set controls. The report also provides an update on the current state of key criminal groups and an outlook of expected future patterns building on a deep-dive analysis of various reports and studies. It also identifies key exposed countries based on economic size for both the generation of the proceeds of crime and the amounts potentially laundered. Specifically, Chief Compliance Officers will find the report as a valuable source for providing meaningful reporting to upper management including their CEOs on issues that ought to take the center stage while also providing a toolkit for measuring exposure to evolving risk dimensions their radar might have otherwise missed. The report concludes with offering key recommendations for enhancing the global fight against financial crime including as it relates to international cooperation and an overhaul of regulatory regimes to accommodate the changing combating financial crime landscape. In short, the report provides a great resource for combating financial crime professionals in crafting stronger financial crime compliance controls as a way to reinforce the strength, safety, and integrity of the financial system.” 

– by JIm Richards, CEO RegTech Consulting and former BSA Officer, Director of Financial Crimes Risk Management at Wells Fargo & Co, “John Cusack’s Global Threat Assessment is a quantum leap forward in the global fight against financial crime. I cannot improve upon what Sir Iain Lobban so eloquently writes in his introduction to John’s Threat Assessment: “it is a highly impressive compendium of information from multiple sources, harvesting a wide range of studies by reputable authorities, generating a comprehensive view of the threats and trends, of the potential scale and ingenious variety of financial crime around the world today.” Notably, though, and in addition to John’s brilliantly researched and detailed assessment of the key markets, countries, methods, and groups, are his authoritative observations and recommendations, all based on twenty-plus years as one of the world’s preeminent financial crimes compliance professionals.”

– by Sarah Runge, Global Financial Crimes Compliance Head of Regulatory Strategy at Credit Suisse, and formerly until 2018 at the the U.S. Treasury Department’s Office of Terrorist Financing and Financial Crimes, as Director of the Office of Strategic Policy for Terrorist Financing and Financial Crimes, – “Quantifying and qualifying the cost of financial crime is incredibly difficult.  So challenging, in fact, that it hasn’t been attempted in over a decade.  John Cusack not only estimates the volume of such proceeds, but he breaks it down by criminal markets, exposed countries, money laundering methods, and criminal group to provide the most comprehensive global assessment to date. Thanks to John, not only do we have a description of threats, but a methodology which we can follow and understand. John undertook extensive research to identify information and drew his analysis from over 100 public sources of information in order to publish a truly global threat assessment.  This work will now become the new basis of statistics for estimating the value of financial crime and offers one way forward with thoughtful recommendations.  Thank you, John.”

by Che Sidanius, Global Head of Financial Crime & Industry Affairs, Refinitiv, “This is a seminal paper on the challenges that currently faces the fight against financial crime. Quantifying the scale of illicit proceeds is usually the challenge, and this report does exactly that. It also exposes the fact that the problem is global and that we, across the public and private sectors, need to do better and take a more collaborative approach to make a difference.’

– by Patricia Sullivan, Global Co Head Financial Crime compliance at Standard Chartered Bank, “An early and very dear mentor taught me “if you can’t measure it, you can’t monitor it.” I have shared this advice with many in my teams over the years. John Cusack’s compelling research here is an opportunity to consider and debate if we have the right and complete intelligence to measure financial crime threats. If we are not able to accurately measure the risks, then the tools, solutions, and recommendations to mitigate may be ineffective.”

– by Nic Swingler, Head Financial Crime Compliance for Absa Group Limited as “John’s Global Threat Assessment should be mandatory reading for all Financial Crime professionals.  He has achieved the rare feat of providing the reader with a thoroughly researched, fact driven holistic assessment across criminal markets which seamlessly link into further detailed analysis across countries, money laundering methods and criminal groups.  All of this is presented in a succinct manner and in a format which is easy to follow.  The “cherry on top” is John leveraging his wealth of knowledge and immense experience to provide very valuable and practical recommendations.”

– by Victoria Meyer, Founder and CEO of SIBAcademy, “A must-read for anyone looking for an overview of trends in laundering the proceeds of crime, this FCN Special Edition provides a comprehensive overview of the billions laundered annually around the world and the methods used to move those funds. The analysis of criminal markets, in particular, highlights the advance of organised crime and the growth in demand for laundering of criminal proceeds.An impressive amount of research, covering over 100 separate studies and reports, has been distilled into an accessible summary of money laundering drivers, methods and risks.  This assessment of the available research also points to the worrying conclusion that not enough is being done to analyse global threats, and highlights the need for more coordinated intelligence to drive a new joined-up strategy for fighting money laundering and terrorist finance. 

– by Andrew Williams, Global Head of Compliance at UBS until 2014, leading consultant and coach, John is one of the outstanding Financial Crime professionals of his generation and his Global Threat Assessment demonstrates that rare combination of detailed sourcing and factual analysis with the overlay of decades of practical experience. That, together with a very user-friendly style that make it an invaluable tool for everyone involved in the fight against financial crime and those with a wider interest in the sector. Truly a “must read.”

– by Malcolm Wright, Chief Compliance Officer, Diginex, and Chair of the AML/CTF Working Group for the Industry Body, Global Digital Finance, “A comprehensive review of the landscape of financial crime has been long overdue for some time. Whilst we have seen many individual reports on various predicate crimes such as fraud and human trafficking, alongside the methods used by criminals such as cash, trade-based money laundering or virtual currencies, we have not seen a consolidated bringing together of all of this information. The FCN Global Threat Assessment (GTA) has done just that; bringing the latest estimates on financial crime, and taking a data-driven approach to being able to provide pivots on the types of crime, countries with most activity, money laundering methods, and criminal groups involved. An interesting consideration that the GTA permits is some objectivity around scale. For example, there is considerable debate about the threat posed by virtual currency money laundering. However, against the backdrop of cash ($4.4tn USD), TBML ($1.13tn USD), and Transaction Based Money Laundering ($352bn USD), virtual currency money laundering accounts amounts to $26bn USD. This may be pause for thought; the necessity to prevent financial crime is a given, but as regulators seek to implement effective AML controls in line with FATF Recommendations, the GTA may offer some guidance on ensuring proportionality of controls that are in line with the size and scale of misuse. The GTA looks set to become an important piece of work across the board in assessment of financial crime risk, and to become a resource upon which Compliance and Risk teams, and regulators and Governments can draw supportive data from.”

Whats the GTA About?

This Book relies on more than 100 separately published studies and reports and values that have been established to produce a first ever ranking of the largest criminal markets, and by extension likely Country exposures, methods employed and those benefiting the most, with all values representing 2018 values.

By its very nature, crime operates in the shadows and in so doing avoids accurate empirical assessment, in particular on the size and composition of criminal activity where that activity is being carried out, the laundering of that activity and who benefits.

The purpose of the activity, or the motivation is largely financial gain and those involved willingly flout the law, will not limit themselves to one criminal activity if another can be taken advantage of and will partner with others to collaborate across borders.

Despite the limitations presented in estimating criminal activity designed to be hidden, the results present a bleak picture. Criminal markets are generating more illicit funds than at any other time in our history, with ever more harmful effects inflicted against every country, against billions of people and against our increasingly fragile environment.

As the US approaches its 50 year anniversary since it passed it first AML Laws and FATF this year celebrated its 30th birthday and the G20 extended its mandate indefinitely, it’s worth asking a few hard questions, for example:

* Are we doing enough?

* Is what we are doing working? &

* What could we do better?

Detailed Observations and Recommendations are provided.

GTA - In Pictures

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