Featured Articles

The UK’s Post-Brexit Stand for Human Rights

After much speculation about its post-Brexit role in the fight against financial crime, the United Kingdom took the surprising step in early July of becoming something of a sanctions hawk—at least on paper, that is. In its first divergence from EU sanctions since leaving the bloc in January, the UK… Read More

Questionable Client: Lessons From Deutsche Bank’s Epstein Fine

Banking high-risk clients can can be challenging for the compliance departments of financial institutions under normal circumstances. Banking wealthy, and notorious, sex offenders can be not only difficult, but costly too. Such was the basic lesson Deutsche Bank (DB) learned earlier this month, after the New York State Department of… Read More

The Master Identity Thief: How Dartanyon Williams Stole Millions by the Age of 23

By the time Dartanyon Williams was 15-years-old, he was already an identity thief. At 19, he had begun to recruit accomplices twice his age to help build a criminal enterprise that ultimately netted him $3.1 million before his eventual arrest. What had begun as rudimentary payment card fraud using his father’s… Read More
When the rest of England emerged from its Coronavirus-related lockdown on 4th July 2020, one city that remained locked down was Leicester and it was the only one to do so.  The city was said to be experiencing an unexpectedly higher number of infections, purportedly originating from workers in… Read More
On July 8th, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Amazon.com, Inc (“Amazon”) for a large number of violations across a wide spectrum of OFAC’s sanctions programs (the agreement published by OFAC lists 14 sets of regulations and Executive Orders). While the total amount… Read More
Growth in cryptocurrency adoption in recent years has attracted public interest, investment opportunities and regulatory attention. While cryptocurrency-related headlines are now commonplace, cryptocurrency mining remains an obscure topic to most. Anti-financial crime professionals familiarizing themselves with cryptocurrency risks should be certain to focus on what may appear to be a… Read More
The recent Civil Monetary Penalty (CMP) imposed by the Office of Foreign Assets Control (OFAC) on BIOMIN America (“BIOMIN”) seems appropriate, although the stated reasons for the penalty’s amount seem strange, given the facts in evidence. However, if you re-examine the entire fact pattern, there are better lessons to… Read More
If criminals have the advantage in the fight against financial crime, that’s due in no small part to how the anti-money laundering sector functions, according to Jim Richards, principal and founder of RegTech Consulting LLC. For one, bank supervisors are focused primarily on technical compliance with AML regulations rather than… Read More
The suspicious activity reporting regime is in need of a “wholesale revolution” that would allow financial institutions to deliver more actionable intelligence to investigators, according to Tom Keatinge, director of the Centre for Financial Crime and Security Studies at RUSI. In a recent episode of KYC360’s AML Talk Show,… Read More
If filing a suspicious activity report is more of an art than a science, it should be remembered that not all art is equal. Like a painting hung in a museum, a good SAR must be the product of focus and intention if it’s to engage its intended audience. For… Read More
Don’t accuse whistleblowers of being in it for the money. So says Tom Mueller, author of Crisis of Conscience: Whistleblowing in an Age of Fraud, during a recent episode of KYC360’s AML Talk Show hosted by Martin Woods. “The vast majority of whistleblowers that I interviewed, their… Read More
Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and… Read More
At times it can seem as if Swedbank’s recent history has been taken from the plot of a Nordic noir novel. There is a procedural bleakness to the Swedish bank’s money laundering scandal and a complexity to it all that does little to resolve the moral ambiguities of institutional malfeasance. Read More