AML Conversations: An interview with the former FinCEN Deputy Director
John Byrne sits down with former FinCEN Deputy Director, Jamal El-Hindi and now Counsel with Clifford Chance. The two discuss AML challenges with new technology, the use of data, sanctions issues and his 20 year career at the US Treasury Department.
AML Voices: Domestic Terrorism: Taxonomies of Radicalization
Our expert panel discusses the process of radicalization and the related changes in financial activity that individuals go through as they move along the steps from sympathizer to terrorist.
The Suspicious Activity Report that is Not Suspicious – Marijuana Limited
As a former Bank Secrecy Act (BSA) Officer I understand that BSA requirements are intended to ensure the integrity of the banking system and detect and deter money laundering. My experience has also shown me that the most important output of a BSA program is its suspicious activity reports (SAR). A well prepared SAR will provide actionable intelligence for law enforcement to use in starting or bolstering investigations and prosecutions.
Trouble in Paradise? Understanding Risks of Financial Activities in The Cayman Islands
At a glance, the Cayman Islands may simply appear to be a small collection of islands located in the Caribbean Sea with less than 100,000 residents that are only notable for being a British Overseas Territory. These looks can be deceiving, since despite the Cayman Islands’ small population and geographic footprint they are a major international financial center. Per the 2019 Mutual Evaluation conducted by the Financial Action Task Force (FATF): “The Cayman Islands boasted the 6th largest banking sector in the world with a cross border asset position valued at $1.365 trillion dollars and was the 5th largest financial jurisdiction by cross border liabilities valued at $1.347 trillion” (Risks and General Situation, 8). Why the Cayman Islands is such a large international financial center is due in part to the ease of operating a business in the Cayman Islands – the territory famously lacks any taxation on corporate profits, capital gains and personal income for corporations and individuals who operate within the territory (Chon, 2). Additionally, the Cayman Islands has notably relaxed regulations for entities operating within its jurisdiction.
Understanding global corruption and how to prevent it
Corruption can lead to ethical and reputational problems at a private and public level, heightening the need for recognition across the globe about how to both report and prevent it. At the end of 2021, the Biden Administration announced their plans for an anti-corruption strategy to tackle corruption’s ‘ability to corrode democracy’. This echoed other foreign governments around the world which have sought methods to mitigate risk and combat corruption. There have been developments across the globe to combat corruption in recent years, which helps draw conclusions for financial institutions on how to mitigate risk; we can offer solutions to help with these risks.
FinCEN Issues Advisory on Kleptocracies and Foreign Corruption
On April 14th, the Financial Crimes Enforcement Network (FinCEN) issued an advisory on kleptocracy and foreign public corruption. This alert urges financial institutions to make a concerted effort to detect any proceeds of Russian or other foreign corruption. This foreign public corruption includes bribery, embezzlement, extortion, and misappropriation of public assets. This guidance comes following the sanctions against both entities and individuals after Russia’s invasion of the Ukraine.
AML Voices: High Risk Customers: How Do You Use Risk Ratings?
Our expert panel discusses how to use risk ratings in formulating a financial crime prevention risk assessment, including how to take into account the variations in risk ratings based on lines of business and geographies.
What are the money laundering risks surrounding migrant smuggling?
Migrant smuggling arises due to global conflict, including fleeing from war, political instability, and violence, as well as a yearning for better opportunities and quality of life. This desire is capitalized by smugglers to use migrants as a source of profit, with this illegal industry having estimated annual profits exceeding $10 billion, according to the Financial Action Task Force (FATF). More recently, the disastrous conflict happening in Ukraine has forced citizens to flee and seek refuge in neighboring countries.
AML Conversations: How financial institutions can help prevent human trafficking
For this episode of our AML Conversations podcast, we sit down with Sara Crowe, the strategic initiatives director at Polaris, a non-profit working to end human trafficking. We discuss how human trafficking has evolved in recent years and concerns following refugees fleeing Ukraine, as well as actionable insights for financial institutions as to how they can help prevent human trafficking. We hope you enjoy this episode.
