On a recent trip to Australia, Financial Crime News caught up with ANZ’s Guy Boyd, now Chief Compliance Officer, in Melbourne, with responsibility also for Financial Crime Compliance. In this interview Guy answers questions on ANZ, the threats and risks facing Australia, New Zealand and the wider Region, challenges and opportunities and highlights the work of the Fintel Alliance, the public private partnership making great strides and an example to many. For more information from FCN on Country Threats on Australia see HERE, and on New Zealand see HERE:
1 FCN: What’s your current role and how did you get to this position?
GB: Since July this year I have been ANZ’s Chief Compliance Officer. Interestingly, I moved from private legal practice to ANZ in 2006 in its legal team and later into the Risk function to work on establishing a sanctions compliance response and capability.
On a recent visit to South Africa, Financial Crime News was delighted to meet with Nic Swingler Head Financial Crime Compliance at Absa Group Limited, who in an interview discussed the fight against financial crime on the African continent and in South Africa in particular.
FCN: How did you come into your current role?
NS: I am not a Financial Crime “lifer” and this role was not really part of my early career planning! Previously I was the COO for our Corporate & Investment Bank. The front line experience I gained over many years as well as direct exposure to products, operations, technology platforms and data were amongst the key attributes required to enable and deliver a high quality risk management capability across Financial Crime Compliance.
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.
Whilst the term “organised crime” appears to have emerged in Chicago in 1919, the phenomenon of organised criminal activity far pre-dates this and its manifestations have developed considerably since that time. Examples include “thugs” or gangs of criminals, who terrorised 13th century India moving from town to town, looting and pillaging and “piracy” on the high seas, and highwaymen and banditry to the pre-industrial world what organised crime is to modern society. Many of today’s leading organised criminal gangs also have long histories, many tracing their origins back to feudal times, retaining links and codes from a bygone era whilst at the same time modernising and expanding their operations far beyond their traditional roots from their homelands across the world.
Whilst prohibition on alcohol in the US was presented as a victory for public morals and health, it was to prove a temporary measure being repealed in 1933.
Having attended the FATF Consultative Forum on the 6-7th May, 2019, I was invited to present on “the latest trends / priorities in the Public and Private Sectors on AMLCTF.” Here is a brief summary of my presentation, which is based on work progressed within the Wolfsberg Group.
Modernising the Fight against Financial Crime
As we seek to modernise the fight against financial crime, we need to put “effectiveness” ever more at the centre of what we do. For FI’s technical compliance assessments are extremely challenging but also fail to measure contribution or effectiveness. In order to support improved effectiveness the areas that need additional attention include (see chart below):
Whilst there is no silver bullet, real progress is dependent upon a common understanding of what outcomes we want to achieve and what then should be the priorities. Continue reading
The Bank announced on 9th April, 2019 resolutions with US and UK authorities regarding its historical sanctions and financial crime controls, which mostly related to violations and control deficiencies pre 2012 with none occurring after 2014. More details on these resolutions can be found on the Banks’ dedicated Fighting Financial Crime website: which also includes new pieces of work on “Antiquities Trafficking,” “Understanding digital identities in a world of cyber crime and compliance ” and “Iranian Virtual Currency Activity and risks to FI’s.”
SCB’s Fighting Financial Crime website is a good source of information to implement controls and processes to modernise the fight against financial crime in the area of cyber, data management, information sharing and more.
As the only thing certain apparently is uncertainly (unless you count death and taxes) only a fool would predict anything. So foolishly here are my top 10 predictions for 2019 – in the fight against financial crime.
- Crime will remain a top 10 global industry and the most profitable of all industries (due to extremely low levels of interdiction) but fall to 2nd in the list of none financial risks of concern to FI Board’s, after Cybersecurity. Depending on your definition of financial crime estimates range from USD2.1 trillion a year, though these likely understate the amount, particularly as they are based on classic financial criminal proceeds, such as drug trafficking and organised crime and date back to 2011. The figures could include corruption (IMF estimate USD1-1.5