In this Interview, Financial Crime News caught up with Graham Hooper, just after the announcement that he had been awarded an OBE for his services to fighting financial crime. No one deserves such an honour more than Graeme. Graeme talks about what he’s doing now, his role in helping to drive change via Public Private Partnerships, the Convergence of Fraud and Financial Crime, challenges for Heads of FCC as well as his one wish for the future in this space.
Graham Hooper has over 35 years experience of developing and implementing security and financial crime prevention strategies in both public and private sectors. He retired from Lloyds Banking Group in December 2017 where he was Financial Crime Risk Director and Deputy Group MLRO. He has held similar roles at both Barclays and Alliance & Leicester and in other counter-organised fraud and security-related positions. He currently works part-time as a financial crime prevention consultant.
Graham has worked with a wide range of government, regulatory and investigative bodies. He was Chair of UK Finance’s Money Laundering Advisory Panel (MLAP) and the UK Retail Banks’ representative on the Government’s Money Laundering Advisory Committee (MLAC). He was also Deputy Chair of the Joint Money Laundering Steering Group (JMLSG) and a member of the Management Board of the Joint Money Laundering Intelligence Taskforce (JMLIT). He was appointed an Officer of the Order of the British Empire in the Queen’s 2019 Birthday Honours List for services to tackling financial crime.
FCN: After a lifetime dedicated to fighting financial Crime your efforts have been rightly acknowledged – tell us about the award and what it represents?
GH: It came as a huge shock and a wonderful surprise. I have been deeply touched by the generous good wishes of family, friends and colleagues since the announcement and very grateful to those who took the time and effort to support my nomination. The award reflects a long-term contribution to the development of national policy and global best practice and work in leading industry efforts to ensure a collective understanding of the challenges faced and in seeking pragmatic, risk-based solutions. I hope it also represents my passion for the subject, my motivation for mentoring and a long-held belief that protecting customers, the economy and society in general from the harm caused by financial/organised crime and terrorism is predicated on a strong, collaborative and trusting public/private sector partnership at both policy and operational levels.
FCN – What are you up to and what keeps you interested in the fighting financial crime space?
GH: I am thoroughly enjoying “keeping my hand in” by providing consultancy services to a number of large and small accounting firms. This gives me the opportunity to use my knowledge and skills to benefit a wide range of clients across a broad spectrum of initiatives. It also helps me keep abreast of the latest developments in the financial crime space as well as keeping the old “grey matter” working! Financial crime prevention has, as you know, always operated in a dynamic environment where threats, risks and typologies change rapidly and I see absolutely no change to that in the future. Technological and economic developments such as crypto-currencies, digital identity and open banking (to name but a few), bring with them the need to implement innovative, technical compliance enhancements to counter the new and emerging crime-tech threats. The challenge of how firms deliver this (often globally) in an effective, efficient and customer-focussed way whilst meeting all legislative and regulatory requirements, keeps me very engaged and interested.
FCN: We hear a lot about convergence when it comes to fraud and financial crime – is this really that new – you seem to have been covering both for much of your professional career?
GH: It’s certainly not new but early in my career I remember the generally held premise that fraud is an attack on the bank, money laundering is through the bank and terrorism occurs after the bank. For me, this paradigm shaped the way we’ve historically viewed fraud and financial crime threats and responded to them. The industry created separate skill-sets, developed different operational processes and implemented dedicated technology to support compliance measures for both disciplines. I think there was a delay in acknowledging the true nature of predicate offences and in developing and implementing a holistic response to “all crimes” legislation. The emergence of typologies such as Money Mules and Authorised Push Payment (APP) fraud and the increasing focus on the impact on victims, has served to further blur this traditional distinction as well as to sharpen the need for a different approach.
The capability to align these disciplines successfully is improving with the development of new data management technologies that help deliver an enhanced single customer view and with the increasing adoption of intelligence-based approaches to risk management that identify linkages in pooled data.
FCN: Geopolitics is intertwined with fighting financial crime, terrorism, sanctions and even tax, so have these linkages helped or complicated the effort?
GH: Both – but overall it has undoubtedly helped the effort. Financial crime is a global, trillion-dollar industry and many of the associated risks are shaped by geopolitical changes (e.g. from the activities of Russia, China, Iran etc. and issues such as the on-going migration crisis to the uncertainties of Brexit). These bring uncertainty both for businesses and compliance efforts. Many countries include extraterritorial provisions in their domestic legislation that inevitably create tension with other domestic regimes but this does help serve to raise risk awareness and compliance standards. Groups such as the FATF through its recommendations and mutual evaluation programme and the Wolfsberg Group through its standards and guidance continue to have a profound, positive impact in addressing financial crime by harnessing the knowledge of global SME’s to develop common, global standards and help practitioners navigate a path through sometimes conflicting requirements.
FCN: You have had a long association with in particular those in the U.K. fighting financial crime from advocating and supporting JMLIT and now UK SAR Reform – tell us about your role?
GH: Advocating SAR reform and supporting the establishment and development of JMLIT have been particularly important to me. My role in both was to help consolidate Industry views and to work with Government, law enforcement and regulators to influence the development of pragmatic, sustainable solutions to inherent legislative, policy and operational challenges. The nature of UK POCA legislation has created an environment where increasing numbers of low-quality SARs are submitted to the FIU. Resource and effort is wasted by the reporting sector in generating large volumes of SARs that law enforcement cannot exploit. In order to improve the effectiveness of the regime it is essential that we continue to work to develop new guidance, harness the power of new technology and implement an intelligence-based operational approach where public and private sectors work jointly to investigate quickly those reports that reflect more serious criminal activity.
FCN: The UK had just published its refreshed Economic Crime Plan – What do you make of it?
GH: It’s comprehensive, ambitious and forward thinking. It consolidates previous commitments for addressing economic crime in the UK and contains clear strategic priorities and associated action plans. I think it represents a step-change in how economic crime is understood and addressed. It is great to see that it puts effective public/private sector partnership and information sharing at the core of the strategy and acknowledges that effective risk identification; technology/data; SAR reform; capability and a risk-based approach to supervision are essential precursors to successful delivery. As always, ultimate success will depend on delivering on commitments.
It will be essential therefore to build quickly on established initiatives and get immediate traction on new elements. Sufficient, sustainable public and private sector funding will make the difference between make or break.
I urge everyone to read it – we should have had this a long time ago!.
FCN: What are the biggest changes you have seen and predict will happen in the fight against financial crime?
GH: The days when the MLRO was someone who managed AML/CTF part-time off the side of their desk is long gone. As a great man and much-missed friend/mentor once said: “I operate as a ‘one man and his dog’ operation…and the dog has mange!” The maturity of the ‘all-crimes’ regime, the sophistication of the global financial system and the increasing use of technology by both individual and organised criminals now requires an MLRO to have all the compliance tools readily at their disposal if they are to manage both personal and corporate risks effectively. Financial Crime Compliance needs to be planned as a career choice – rather than something that you wake up one day and find yourself doing! In the future I see an increasing need for high-quality, readily accessible data upon which an intelligence -driven compliance regime can be built. Cybercrime will no doubt come fully into the financial crime aegis as criminals increasingly use legitimate shopping sites to process payments for illicit goods or services. I envisage increased global focus on UBO transparency and progressive steps to regulate virtual assets. The economic sanctions landscape will become even more complex and regulators will increasingly expect firms to demonstrate that they not only have the systems in place to monitor for illicit activity but also be able to prove that they are effective.
FCN: In terms of strategic thinking, what should a leader in Fighting Financial Crime be thinking about?
GH: Effectiveness, efficiency and positive customer outcomes – these are the key pillars of a successful financial crime strategy and every thought should be tested against these. Amongst the questions I would ask myself would be: how can the incorporation of current and future technology help leverage in these areas (e.g. artificial intelligence, machine learning and automation)? How do I build-in extensibility to systems? How do I ensure the confidentiality, availability and integrity of customer and payments data? How can I make a convincing case for securing the necessary funding over the long-term (e.g. can I demonstrate that the tactical solutions I implement in the short-term can form part of a successful roadmap for delivering the strategic vision)? How do I attract and retain the skills and talent I need to deliver the strategy against a backdrop of increasing demand for compliance professionals? How do the deliverables align with my firm’s over-arching business strategy and how will it support my government’s economic crime priorities.
FCN: If you could wave a magic wand and make one wish come true – what would it be?
GH: That the UK’s Economic Crime Plan has just been successfully delivered!