Assurance – Interview with Natalie Merrylees
FCC Leaders Interview: Assurance & Testing – An Interview with Natalie Merrylees
Financial Crime News sat down with Natalie Merrylees to discuss her thoughts on the purpose, challenges, opportunities and the future of Assurance, as well as the importance of trying to identify “hotspots. weak spots and blindspots,” the use of technology, regulatory expectations and much more besides.
FCN: What is the purpose of Assurance?
NM: Assurance provides a semi independent spotlight to reconfirm whatever needs to stay working, is working, or alternatively, is a whistle to gain attention when problems are Identified or aren’t being fixed. In many organisations right now, this role is one of oversight of the firm’s policies and procedures, working to a defined framework and method, and taking its baseline data from the Firms own risk assessment activity
FCN: What do you mean by Semi-Independent
NM: By Semi Independent I mean, we are part of the second line of defence that provides a programme of ongoing monitoring and testing of both the business’s financial crime controls, some of which are carried out of course in the second line.
Traffik Analysis Hub – Interview with Neil Giles
Human Trafficking is a global problem, effecting the lives of millions of people. Traffickers deceive women, men and children from all corners of the world and force them into exploitative situations every day. Whilst the best known form of human trafficking is for the purpose of sexual exploitation, hundreds of thousands of victims are trafficked for the purposes of forced labour, domestic servitude, child begging or the removal of their organs.
In this interview, Neil Giles explains to Financial Crime News, why as programme manager of the Traffik Analysis Hub it has the potential to be a real game-changer in the fight against modern slavery and how information sharing, technology and collaboration are at the heart of this initiative.
FCN: How big is the problem of Human Trafficking?
Wildlife Trafficking Syndicate ensnared by United Forces
On 13 June 2019, the US Department of Justice, U.S. Attorney’s Office, Southern District of New York indicted four individuals, Moazu KROMAH, Amara CHERIF, Mansur Mohamed SURUR, and Abdi Hussein AHMED charged with participating in a conspiracy to traffic more than US$7 million in rhino horns and elephant ivory. In addition, KROMAH, CHERIF, and SURUR were charged with conspiracy to commit money laundering, and SURUR and AHMED were charged with participating in a conspiracy to distribute and possess with intent to distribute more than 10 kilograms of heroin. One of those charged is now in the US, another awaiting extradition in Senegal and two remaining Kenyans still at large, on the run.
This is not just important in terms of the action taken but how co operation across agencies and between public and private sectors and effective information sharing made a difference.
Crypto asks for more effective AML regulation – by Malcolm Wright
In February 2019, FATF issued its proposed recommendations for AML governance of the crypto industry. Under pressure from the international community, the FATF aimed to bring amendments to Recommendation 15 (New Technologies) into force at the June 2019 plenary. Within the proposals, one point was opened for consultation; colloquially known as 7(b) the proposal seeks to introduce wire transfer recommendations required of the traditional banking sector into the crypto industry. That is, originator and beneficiary information is collected, screened and transmitted between correspondent institutions with the objective to prevent criminals and terrorists having unfettered access to the financial system.
The crypto industry responded but not for the reason many thought; the response was not to fight against regulation or kick the can down the road for another day but to make sure that the regulation could be effective.
Financial Access is Essential for Modern Slavery Survivors by Commissioner Barry Koch
From the Financial Sector Commission on Modern Slavery and Human Trafficking / the Liechtenstein Initiative by Barry Koch
The staggering estimates that 40 million people are trapped in modern slavery and that forced labor generates $150 billion dollars a year in illicit funds have raised global alarm. It comes as no surprise to those combatting financial crime that thefinancial community intersects with these forms of exploitation in a variety of ways, from unwittingly laundering funds generated by these practices to investment in businesses that have labor trafficking embedded in their supply chains.
The Financial Sector Commission on Modern Slavery and Human Trafficking, known as the Liechtenstein Initiative, is working to put the financial sector at the heart of efforts to identify, target and disrupt these crimes and their root causes.
Reaching the Unreachable by Helena Wood (RUSI)
Attacking the Assets of Serious and Organised Criminality in the UK in the Absence of a Conviction by Helena Wood – published by RUSI
The paper published by RUSI, on June 10th 2019, authored by Helena Wood (RUSI Associate Fellow and formerly of National Crime Agency and Assets Recovery Agency) is a timely assessment of so called None Conviction Based (“NCB”) confiscation approaches focussing on the UK.
The introduction of the Unexplained Wealth Order (UWO) in 2017 by the UK government was intended as a key tool to tackle the national security threat posed by the the tens of thousands of persons linked to the approx 4,500 organised crime groups (OCGs) mapped in the UK and in particular to concerns raised around the proceeds of corruption some say find a too safe a haven in the UK. Continue reading
Message from the Editor / Publishing SSA TA – 2020
FCN Sub Saharan Africa Threat Assessment – Publication is now available: – see below
Recent FCN Publications
FCN Sub Saharan Africa Threat Assessment – 2020: SSA TA 2020 Published 6
FCN Global Threat Assessment – 2019: FCN-GTA.2019.Pub-Final
Previous Publications
Trade Based Money Laundering – Awareness Video
Extract from the Wolfsberg Group: The Wolfsberg Group, with the support of the International Chamber of Commerce (ICC) and the Bankers Association for Finance and Trade (BAFT), launched a short awareness video focussed on Trade-Based Money Laundering (TBML):
This supplements both the 2009 Wolfsberg Trade Finance Principles and the 2017 publication of a more comprehensive paper, produced in close collaboration with both the ICC and BAFT.
While TBML is a serious financial crime threat, and increasingly a means by which criminals launder billions of dollars each year, it is also one of the least understood. As the volume of trade finance transactions provided by non-bank entities (open account transactions) increases, the visibility that banks have of end to end trade finance activity decreases.
Editor’s Summary – FCN2
When I started this Newsletter, I wanted to offer a digestible collection of both interesting and relevant materials to arm financial crime fighter’s with additional tools to help enable them to do their work. Whilst there is no substitute for reading the more detailed articles in FCN2, or across the FCN website, here are short highlights in summary form:
- Important anniversaries in 2019 include FATF at 30, the US sanctions against Iran at 40 following the taking of US hostages at the US embassy in Tehran. Reaching 100, is the use of the term “organised crime” first coined in the US in 1919 to describe the activities of mobsters such as Al Capone and it’s also a century since the criminalisation of harmful drugs worldwide agreed through the 1919 signing of the Treaty of Versailles.
Fighting Financial Crime after Brexit – Part 4 – 5MLD by Andrew Williams
In Financial Crime News – Issue 1 a three part series of articles examined the issues around the UK’s ability to fight financial crime once out of the EU. In this Part 4, the UK nevertheless remains determined to implement the EU’s Fifth Money Laundering Directive (EU 2018/843 or 5MLD), even in a post Brexit environment, which may raise surprise amongst many “Brexiteers” but has been communicated well in advance. Andrew Williams is highly regarded UK Lawyer at Simmons & Simmons, Consultant and former top Legal & Compliance Chief at UBS.
5MLD - What’s new?
Despite Brexit and the “flexible” date of Britain’s leaving the EU, the 5MLD is expected to become law in the UK by 10th January 2020, not least because the UK was one of the main supporters of the changes proposed.
