Global Threat Assessment
by John Cusack
Despite the limitations presented in estimating criminal activity designed to be hidden, the results in the Global Threat Assessment 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.
We are witnessing the transformation of organised crime into very big business, leveraging networks to connect criminal actors, adopting poly criminality, embracing new cyber tools and opportunities afforded by the transformation to digital.
How big, which Countries, by what Methods and by which Gangs, is summarised in this Global Threat Assessment, using over 100 publicly available studies or reports from credible sources, together with personal observations and recommendations from the author.
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.
In this Interview with the Hong Kong Monetary Authority’s Stewart McGlynn, who leads the Regulators Anti Money Laundering Team, Financial Crime News wanted to know more about HK, the risks and threats, de risking, the recent FATF Report, follow up actions, Regtech, PPP and much more besides. The interview reveals that HK has achieved a lot but also has plans to do more, much of which is exciting and offers the prospects for increased efficiency and effectiveness in fighting financial crime.
FCN: HK is one of the largest and most respected international financial and trading centres, but what attributes do you think are necessary to build and maintain this reputation?
SM: There are several key attributes which overlap to some degree and which can be related directly to anti-money laundering work.
As major changes to AML/CTF are being considered and discussed, developments on both sides of the North Atlantic are of particular note, of which the following are of particular importance.
UK authorities have commenced a consultation on adopting – largely wholesale – the EU’s 5th MLD – a significant action in light of the ongoing ambiguities concerning Brexit and one that clearly signals an intent to remain aligned across the continent in terms of approaches to fighting financial crime. The UK Regulator, the FCA, has recently unveiled plans, priorities and activities for the next 20 months including on fighting financial crime. More broadly, the EU has started the process of empowering the European Banking Authority to develop strategic responses to the various scandals in EU jurisdictions, including those impacting FI’s coming out of the various Russia-linked “Laundromat” schemes and revelations from the release of the Panama, Luxembourg & Paradise Papers.
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
In the wake of a number of recent high profile money laundering scandals, that involved EU based Banks, the EU is proposing to extend powers to the European Banking Authority enabling the EBA (which is moving from London to Paris after Brexit) to be able to directly force individual banks to take measures against ML “as a last resort” if national authorities do not act. However, the changes do not create a dedicated agency to counter ML at the EU level, as proposed by some, such as the European Central Bank. If approved, the EBA will have powers to, among others, request national AML supervisors to investigate potential material breaches and to request them to consider targeted actions such as sanctions and address decisions directly to individual financial sector operators if national authorities do not act.
FinCEN Director, Ken Blanca’s presented remarks to the SIFMA AML conference in Feb 2019, were of particular interest in that they focussed on regulatory reform and a recognition that more needed to be done to modernise the fight against financial crime and that innovative and new ways of working would be encouraged and they were being discussed.
On regulatory reform, 5 areas were mentioned, though few concrete details provided. These were:
• reviewing ways in which financial institutions can take innovative and proactive approaches to identify, detect, and report financial crime and meet BSA/AML regulatory obligations;
• reviewing the risk-based approach to the examination process;
• reviewing the agencies’ approach to BSA/AML supervision and enforcement;
• Identifying better ways to communicate priorities and feedback to financial institutions, regulators, and law enforcement; and
• Identifying concrete ways to understand and quantify the value and use of financial institution reporting. Continue reading