Posted in Financial Crime

FATF EU Grey List Countries Compared and Why is Russia not yet Included on either

For those keeping track of countries listed by FATF & the EU both institutions have updated their lists recently with the FATF on 24th February and the EU on 20 December 2022 (see below for the current status – which for the EU came into force for newly added countries just this week on 16th March, 2023).

FATF removed Morocco, Cambodia and added Nigeria and South Africa. The EU added The Democratic Republic of the Congo, Gibraltar, Mozambique & the UAE and removed Nicaragua, Pakistan and Zimbabwe. Of added interest, the EU list doesn’t include Albania & Türkiye (both on the FATF list) and has yet to delist Cambodia and Morocco or add Nigeria and South Africa but these are likely to happen over the next 12 months.

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Posted in Financial Crime

Kenya Financial Crime Dashboard 2023 by FCN

Following the publication of the FATF 4th Round Review and Report for Kenya, Financial Crime News has updated its Kenya Financial Crime Dashboard last published in February 2022, in its new 2023 format.

This new format includes, for example approx 150 data points which have been collected and are represented in the 2 page Financial Crime Dashboard. It informs as to the nature of the financial crime threats, the main vulnerabilities, how resilient Kenya is to these threats and its overall level of response, with more KRI and KPI data than ever before, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN. 

For a copy of the 2023 Kenya Financial Crime Dashboard see HERE: Kenya Dashboard 16:3:23 Pbd

For a copy of the 2022 Financial Crime Dashboard for Kenya see HERE.

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Posted in Financial Crime

France Financial Crime Dashboard 2023 (Update) by FCN

Following the publication France’s AML/CTF National Risk Assessment in February 2023, Financial Crime News has updated its France 🇫🇷 Financial Crime Dashboard.

This France Dashboard is in the 2023 format from Financial Crime News, which includes, for example approx 150 data points which have been collected and are represented in the 2 page Financial Crime Dashboard. It informs as to the nature of the financial crime threats, the main  vulnerabilities, how resilient France is to these threats and its overall level of response, with more KRI and KPI data than ever before, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN.

For a copy of the Detailed France Threat Assessment 2022 see HERE & for the 2022 Financial Crime Dashboard for France see HERE.

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Posted in Financial Crime

Where are the Sanctioned Russian Assets Frozen in the West and How Much is actually Frozen?

Introduction

On the eve of the anniversary of the Russian invasion of Ukraine, the question of what we should do with the approx US$300 billion of Russian Central Bank assets and US$30 billion of assets of Oligarchs & Officials close to the Russian leadership estimated as immobilised and or frozen in Western countries, is being actively considered.

Whilst it’s a more than a reasonable suggestion that these assets should be used to aid Ukraine in its defence and for future reconstruction once Russia is defeated, decisions as to whether this is legally possible and can be achieved is actively being discussed in Washington, Ottawa London, Tokyo, Canberra, Bern and Brussels in particular. Also whether the answer is different for funds immobilised from the Russian Central Bank or from assets seized from private persons such as Russian Oligarchs and or officials is yet to be clarified.

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Posted in Financial Crime

The Wolfsberg Group CBDDQ V1.4 2023 Assessment by FCN

The revised and updated Wolfsberg Group CBDDQ V.1.4. and supporting materials were published on the 10th February, 2023. This journey started with the original AML Questionnaire issued in 2004, updated in 2014 and in 2018 (all 3 worked on by the author) and in 2020 and now in 2023. As important is the release of the shorter FCCQ, which is used for non correspondent banks and updates and consolidation of essential completion guidance.

Focussing on the CBDDQ, the number of questions increased from 28 to 110 headline questions in 2018. The 2023 Version takes the number of overall headline questions from 110 to 132, suggesting this is much more than a technical upgrade and  represents sensible incremental improvements also reflecting a changing financial and financial crime landscape. 

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Posted in Financial Crime

Fraud in the UK – Part 2 – Payment Fraud & Scams against Individuals & Businesses

Payment Fraud & Scams against Private Persons & Businesses – Focus on UK 🇬🇧

1. Introduction:

Fraud is probably the most commonly attempted and or experienced crime in the world. Fraud encompasses many activities but at its core involves an attempt to steal, ultimately for financial gain. This includes dishonesty or deception, but under law is frequently a separate offence from theft, with less elements in order to prove and or to convict.

Whilst in many cases a “fraud” can be attempted and successfully carried out against a victim without the victims involvement or active knowledge, “scams” usually involve in some way the victim’s unwitting participation.

As more activities move online or are accessed through digital channels, the availability, speed, cost and ease of use provides significant benefits, but at the same time offers ever increasing opportunities for criminals to benefit, either by obtaining personal credentials to make payments and or acquire goods using victims moneys where they have no knowledge of the activity until after the event, or by tricking the victim through a deception and the victim authorising or involved in a payment they would otherwise not agree to.

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Posted in Financial Crime

Fraud in the UK – Part 1 – The Fraud Response for over Five Decades

Fraud in the UK & the UK Fraud Response over the last 5 decades

Fraud has been in existence for more than twenty centuries. This paper summarise the important developments in the response to fraud in the UK over the last 5 decades, as we have moved from the analogue to the digital age, financial fraud has become more prevalent and ever more sophisticated – this ahead of the UK Government’s keenly awaited Fraud Strategy, expected to be published shortly.

Since the late 1980s, advances in technology have seen fraud evolve into more complex forms- from handing out bad cheques and fake currency to replicating credit cards. The internet & other mobile channels such as mobile has changed the world, and it is now available to anyone with access to a computer or smart phone.

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Posted in Financial Crime

Sanctions on Russia by C7 Countries

It’s hard not to hand the equivalent to the golden globes or OSCARs to sanctions as the top issue in 2022, with cryptocurrency and transparency of beneficial ownership noteworthy concerns and continued focus of attention in the fight against financial crime. As the Russian tanks rolled into Ukraine on the 24th February 2022, resistance from Ukraine and support from the West has halted the advance and appears to be providing the Ukraine with a viable route to take back their lands and push the Russians back from 21st century importance. Whilst huge credit goes to the Ukraine, the support from in particular C7 Countries has been invaluable. Whilst they don’t share a battlefield with Ukraine they have all seriously stepped up, not least in implementing sanctions.

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Posted in Financial Crime

Human Trafficking Conviction Data Updated

This post is supplemental to a post published on 28th October 2022 Human Trafficking Cases – Prosecutions & Convictions Analysed by FCN. after publishing the data for the previous post, FCN has carried out further research to look more deeply at the HT conviction numbers and to control for population and threat. This provides a different prism to look through and produce KPIs and one that has more merit than simply looking at absolute numbers. Again the focus is to look at FATF member countries plus Indonesia and the UAE.

Human Trafficking Conviction Data – Updated to reflect Threats

Today, like every other day of the year an estimated 50 million people (6.4 out of 1,000 people) including 3.3 million children are enslaved in either sexual or other forced work or marriage (estimates from ILO/UNIOM/Walk Free 2021 – up from 40 million in 2016).

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Posted in Financial Crime

The Future of Cross Border Payments – Removing Friction from Sanctions Screening

Introduction

In 2010, the fastest way to move money on the same day from London to New York was to catch a flight from Heathrow to JFK and deliver it yourself. The average time a cross border payment now takes is 2 hours (quicker than taking the flight at around 7 hours) but some do take much longer. The industry goal is to move towards instant payments across all cross border payment corridors, similar to domestic faster payments that are regularly settled in many countries in under 10 seconds. Speeding up cross border payments is important, but also important is reducing costs and providing access to all.

The journey to achieving greater access and faster and cheaper payments is underway, with the Financial Stability Board targets set for the end of 2027 just 4 years away and still looking ambitious.

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