Introducing FINTRAIL Pioneer

FINTRAIL Pioneer is here  - the latest edition to our service offering designed to help businesses, no matter how small, in the fight against financial crime. 

Pioneer will sit within our global FINTRAIL Consult team, leveraging our specialist knowledge and passion for financial crime prevention to start supporting a new range of clients who have previously found it harder to access bespoke and considerate anti-financial crime services. 

So what does this mean in practice? Well: 

FINTRAIL firmly believes that excellent financial crime prevention starts from the ground up. Anti-financial crime (AFC) controls need to be built into your product and culture from the word go to limit bad actors exploiting your product. To help you, FINTRAIL Pioneer makes our consulting expertise easily available to small businesses, and early-stage startups (we’re talking less than 10 employees, or a balance sheet of around £2million or less) to support you in building a robust AFC program right from the start. 

We also understand that financial crime does not limit itself to only the financial services sector, so we’re expanding our Pioneer services to the Not-For-Profit (NPO) sector to support them in delivering crucial work for those most in need, free from the threat of being exploited by financial criminals.  

Lastly, our team  is driven by a shared passion for disrupting financial criminals and the crimes they facilitate across the globe. Pioneer will be uniquely responsible for directing that passion towards “for good” projects across the industry, offering our services free of charge to projects where we really believe we can make a difference. 

We’re really excited about Pioneer, and the difference we aim to make in the AFC community.

So if you are a small business, early stage start-up, or NPO and need support with your AFC obligations, or have a “for good” project you’d love to chat about then please get in touch – we’re all ears. 

Introducing FINTRAIL Consult

November marks my third year at FINTRAIL, and whilst three years certainly isn’t a major landmark to be celebrated, upon reflection, the last three years have been an incredible journey. Over the last 18 months alone we have delivered over 200 financial crime projects to support a  variety of different organisations. We have also seen the FINTRAIL team grow and develop, and we are in the process of adding another 10+ people to the family.

Yet there is more still to be done. Rob mentioned in his “Change is coming” blog last week, we are making some exciting changes at FINTRAIL to support the industry further. Under the new banner of ‘FINTRAIL Consult’, our consulting team is dedicated to offering a best in class anti-financial crime consultancy service to whoever may need it. 

The last 18 months have taught us that collaboration is key to delivering high quality products and services to our clients.  We will be joining our teams together under one global banner of ‘FINTRAIL Consult’ whilst continuing to add depth to our consultancy team with both regional and subject matter knowledge. This means our clients will receive a more consistent service and have access to all the knowledge within our team regardless of where they are located.

To ensure we support our client’s aspirations, we have also made some internal changes. Jessica Cath has been promoted to Head of Financial Crime Project Delivery, leading the core consultancy team and ensuring we maintain a high level of standards in the services we provide. Alongside Jess, we have expanded Greg Wlodarczyk’s role to Head of Specialist Financial Crime Advisory and Virtual Assets.  We recognise the evolving environment our clients operate within, which means we must also evolve. Greg will be focusing on ensuring the services we provide are progressive and ready to meet new challenges, whilst also working to hire individuals with the right specialist skills.

The new FINTRAIL Consult is looking forward to continuing to work with the financial crime community into 2022 and beyond! 

We are always here if you need us - do reach out if you have any questions

Destination Europe: FinTech Passporting Hotspots post-Brexit

The impact of Brexit on the UK FinTech Sector

London has seen an exodus of firms as a result of Brexit. Five months before the UK left the European Union (EU), banks wrote to British customers living in the EU to inform them that their accounts would be closed by the end of the year. A departure of firms from the UK, including German neobank N26 whose European banking licence would no longer allow them to operate in the UK, then followed.  

Now, UK FinTech firms look towards the EU for countries that offer potentially lucrative passporting services, enabling them to export their products and services to the European Economic Area (EEA) to continue to grow and expand their customer base. 

So where are firms relocating to, and what should they expect? 

Hot destinations post-Brexit

Being authorised in the EU can give FinTechs access to 30 EEA Countries, which bears a collective potential customer base of almost 450 million people. Not to mention the circa 25 million small and medium enterprises throughout the EEA who could be looking for new financial and accounting services. 

In 2019 approximately 275 financial institutions moved a combined total of over £800bn in assets out of the UK to other parts of Europe. Dublin accounted for more than 100 relocations, grounding itself as one of the EU’s biggest FinTech hubs - unsurprising given it’s the European home to tech giants like Stripe and Google. Post brexit, Ireland continues to be an attractive gateway to the European financial and technology sector. 

Lithuania also continues to be a popular choice for FinTech, with approximately 118 fully passportable FinTech licences being issued by the Central Bank. Much like Ireland, the baltic nation has anchored itself as a rising star of the FinTech world with a business-driven regulatory environment and a large pool of FinTech talent.  

So what makes Ireland attractive?

Ireland is renowned as a world-leading centre for the technology industry. The Emerald Isle is a gateway for international technology businesses seeking to enter or serve the European market making it an attractive proposition for FinTech. 

The FinTech sector is a priority for the Irish Governmentas evident from its strategy for developing Ireland’s financial services sector, IFS 2020. The Government is proactively promoting Ireland as a global digital hub. 

As a result, Ireland has already seen a number of large banks move to her shores, including Bank of America, JP Morgan, and Goldman Sachs; but also large FinTech players such as the payment processor Stripe. 

FinTechs looking to set up in Ireland should be aware that the country has a cautious regulatory environment. The regulator tends to err on the side of strict, but very supportive, supervision over business-driven regulation that includes things like sandbox environments, or “lite licensing” programs. Firms will need to be confident their anti-financial crime program will pass muster with the Central Bank of Ireland (CBI) and that they are suitably resourced to cooperate with CBI as part of their oversight (which includes oversight of third party arrangements such as IDV vendors).

On the talent front, Ireland has a wealth of strong tech talent given it’s a strong tech-centric enterprise hub; however, talent is in high demand with the increase of firms looking to move services to Ireland. This could prove problematic for FinTechs as CBI looks for strong local establishment from firms with functions such as the MLRO or Head of Compliance to be local. 

Overall, Ireland offers a stable environment to operate successfully in once licensed (average 6- month licensing time) with access to talent, and thorough regulatory support from the Central Bank. FinTechs moving to Ireland should be prepared to have close and regular engagement with CBI supervisors and ensure that before starting the licensing process their AFC programme is current. Any new regulatory or legal requirements should be quickly incorporated into the programme to remain compliant with the CBI expectations. 

And what about Lithuania? 

At the end of 2020 Lithuania heralded 230 FinTechs licensed and operating in their country, contributing an 18% growth in their overall FinTech services since 2019. 

It’s by no coincidence that Lithuania remains an attractive proposition for FinTechs looking to passport their services to the EU. 

The Central Bank of Lithuania, who issues FinTech licences, has a turnaround time of circa 6-9 months to authorise FinTech under an E-money or Payment license. Challenger banks also have the option of applying for a “lite” license which enables fintechs to apply for licenses with a 5x smaller initial capital requirement. 

Being licensed through the Central Bank of Lithuania also allows FinTechs to access the SEPA network through their direct access API and an ability to use unique IBANs meaning instant access to 36 SEPA countries, with potential to access worldwide payment networks. 

For innovators, Lithuania has a favourable regulatory sandbox environment that allows new and emerging financial technologies to be tested in a live environment. The Lithuanian regulators have also obligated themselves to directly support FinTechs within their first year to become compliant with local regulatory requirements which can be of great value to smaller compliance teams, and fintechs that are new to the European regulatory environment. 

However, the FinTech grass in Lithuania may look green for now, but firms looking to move their operations should be aware that the EU Committee of Experts on the Evaluation and AML Measures and the Financing of Terrorism (MONEYVAL) has placed Lithuania under “enhanced follow-up” with regard to how it is managing money laundering and terrorist financing risk. 

For FinTechs, this could mean that Lithuania will introduce stricter regulatory measures and controls that it will expect firms to comply with, as well as potentially enhanced supervision of firms. Whilst enhanced supervision is by no means an obstacle, it will mean that firms will be expected to have tight financial crime programs and controls to satisfy the Central Bank supervisors. 

So, if you’re looking for a business-driven environment to move your operations to, Lithuania could be the place for you; though it’s important to look to the future and ensure you’re well resourced enough to quickly respond to any changes in the Lithuanian regulatory environment that may result from increased EU scrutiny on their financial crime control expectations. 

I’m interested in passporting. What do I need to think about? 

Whilst different passporting countries offer different services and prospects, one thing that they all have in common is regulatory scrutiny. 

Firms will need to think about whether their current compliance programs are fit-for-purpose in the European regulatory environment. Where new controls need to be added to meet that compliance standard, firms should ensure they are equipped to clearly explain the rationale behind the changes to their customers to avoid any unnecessary friction. A key part of this will also be ensuring that adequate resources like engineering time and compliance analyst time are easily available from the word go.

Companies considering passporting will need to ensure they have their ducks in a row across the business, with particular focus on a robust anti-financial crime framework. It is particularly important to ensure documentation of the  anti-financial crime (AFC) programme, risk appetite, handling procedures, and governance arrangements to demonstrate to Central Bank regulators that a working and current AFC programme is in place. Third-party arrangements such as IDV vendors or customer screening providers will also be scrutinised, so it’s equally important to ensure that outsourcing arrangements are aligned to regulatory expectations in that jurisdiction (particularly in Ireland where regulators will closely review third-party arrangements). 

Regulators will also be looking for detailed risk assessments and associated control frameworks to demonstrate a clear understanding of the risks and the necessary controls in place to mitigate those risks. 

FinTechs also need to demonstrate their compliance and customer teams are adequately staffed to (1) ensure they are equipped to handle customer requests and issues, and perhaps more importantly (2) to ensure they are able to monitor and quickly respond to suspected instances of suspicious activity on their platform. This will demonstrate to regulators that they do not create additional financial crime risk to the European economic environment. 

Financial crime leadership will need to demonstrate that they are equipped with the necessary skills and experience to manage the anti-financial crime side of the business. Regulators want to have faith that granting access to their financial ecosystem does not bring with it an increase in financial crime. 

Finally, consider using external expertise to help get ready for the passporting process. Consider any support and advice that may be needed on programme changes and implementation before being granted a licence. Whilst the application process for licensing is relatively straightforward, it can be of immense benefit to get an independent view of the AFC programme and whether it is likely to pass the muster of the Central Bank supervisory expectations. 

If you are interested in speaking to the FINTRAIL team about the topics discussed here or any other anti-financial crime topics, please feel free to get in touch with Ishima Romain, Analyst or Mikey Morton, Consultant or email us at contact@fintrail.co.uk.

Love is in the air.. Or is it?

With increasing restrictions placed upon our lives due to COVID-19, millions of people have turned to online dating sites to meet someone and spark human interaction. In some instances, it is genuinely love at first sight, but not in others. In such an emotionally charged environment some enter this not for love but for financial gain and tragically, many stumble upon con artists who are eager to take advantage of people looking to make a connection. The fraudster builds up rapport by making up a story and, once they have established enough trust, moves onto the real reason they are there, asking for money. According to UK Finance, there was a 20% increase in bank transfer fraud linked to romance scams in 2019 compared to 2018. However, the damage to the victim often goes much deeper than the financial loss suffered. Navigating relationships can be fraught at the best of times, but here are few things that may help you identify if it is a scammer or not.

Liar liar

Red flags that might help you spot scammers include:

• Asking a lot personal questions about you while avoiding answering personal questions about themselves

• Trying to establish a bond quickly by telling you “this is the first time they’ve felt like this before”, giving you an endearing pet name or even that they are in love with you

• Preferring to move the communication away from dating websites and towards texting or phone calls as the scammers know that the dating website will have no proof of them asking you for money

• Asking for financial help by making up lies (which is covered below)

• never meeting them in person as they are either “out of the country at the moment” or have made up excuses about why they had to cancel - sometimes these include financial reasons

Scammers are inventive when it comes to creating a facade with which to lure victims. Some frequently used lies by scammers in order to request funds include paying:

• For a plane ticket or other travel expenses

• For surgery or other medical expenses

• Customs fees

• Off gambling debts

• For a visa or other official travel documents

Scammers usually request funds via wiring money, putting money on a gift card, or loading money onto a prepaid card. Scammers know that this way, they can get cash quickly and remain anonymous and the transactions are almost impossible to reverse.

Protect yourself

Never send money to a romantic interest you haven’t met in person. If you suspect a romance scam:

• Stop communicating with the person immediately

• Do a search for the type of job the person has to see if other people have heard similar stories. For example, you could do a search for “UK Army scammer”

• Do a reverse image search of the person's profile picture to see if it’s associated with another name or with details that don’t match up

• Contact Action Fraud on 0300 123 2040

If you’d like to learn more, please contact Ishima Romain, consultant or email us at: contact@fintrail.com.

FinTech and Law Enforcement partnerships

Expert Working Group Topic 2: Law Enforcement partnerships

We’ve just wrapped up our second Expert Working Group, following last year’s EWG on FinTech Approaches to Sanctions Regimes. This time, we gathered 16 experts from FinTechs along with law enforcement leaders to chat about our partnerships with law enforcement.

This working group made it clear that finding the right contact or information can be tricky. Please do not hesitate to reach out to the FFE secretariat at ffe_admin@fintrail.co.uk if you need help making contact on an important law enforcement matter—this goes for law enforcement, FIUs and FinTechs. We’re happy to help you find the information you need, quickly.

A sneak peek into just a few of the insights that came from our discussions, which covered FinTech best practices for receiving and responding to requests, SAR feedback, asset freezing, stay-open requests and more: 

• Public/private partnerships and industry groups are tough nuts to crack—58% feel they’ve struggled to get traction with groups that share high-value law enforcement information

• We hear from law enforcement a lot. Half of us receive several requests per week.

• MLROs rarely act as the central point of contact. If you’re an MLRO, and you’re still taking all the phone calls, delegate away—today is your day!

Check out the full report for more, and reach out to us at ffe_admin@fintrail.co.uk to share any insights of your own. And, of course, stay tuned for further Expert Working Groups!

FINTRAIL MONTHLY REG-CAP Jan 2021

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

January 2021

This RegCap summarises any regulatory updates within January 2021.

Some highlights include the update of the Corruption Perception Index being published and a paper from RUSI on the impact of fraud on the UK’s national security landscape.

What other regulations changes caught your eye in January?

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

A look forward: what does 2021 have in store for the anti-financial crime community?

2020 was a rollercoaster for us all, not least professionals in the anti-financial crime (AFC) space who had to deal with regulatory change continuing, and criminals upping their game and exploiting the pandemic in tragically ingenious ways.  You can read more about the impact of the global pandemic, and other key regulatory and typological developments in our lookback papers from our Europe, Middle East and Africa, and Asia Pacific teams.  But, let’s now take a moment to look ahead to 2021 and what we might expect to see as AFC practitioners over the year and what we plan to do as FINTRAIL. Normally, we shy away from predictions, but nothing could have been stranger than the reality that was 2020, so we thought we would give it a go!

Effectiveness and Outcomes-focussed Compliance

We’ve already started to see a shift in this direction in the AFC community, in both larger, traditional banks, as well as in the FinTech community as the pressure from regulators for firms to achieve good outcomes in financial crime prevention increases.  Even as far back as 2019, the then-interim Chief Executive of the UK’s Financial Conduct Authority noted: “One thing is already clear – we are moving from a narrower compliance with the rules, to a focus on delivering the outcomes we want for the users of financial services.” While not specific to anti-financial crime, it is clear that all financial services firms want good outcomes for their customers, particularly when it comes to preventing crime against them or involving them. 

What is likely to come this year, in our opinion, is a greater focus from regulators on how those outcomes are measured and therefore how confident a firm can be that its controls and AFC risk mitigants are indeed effective at tackling financial crime. Presently, measuring effectiveness can be challenging and is often unsystematic, relying on annual Money Laundering Reporting Officer (MLRO) reports that pull together proxy measures of effectiveness from a wide range of sources, which is manual, time consuming and potentially error prone if the data is not tracked on a more regular basis, and unusual findings pulled out and scrutinised. Using technology to address this problem in the future is at the heart of the solution. In our view, not only will an outcomes focussed approach increase the relevance of reporting that AFC provides to its senior leadership teams - as it will be able to demonstrate clear Key Performance Indicators (KPIs) and markers of improvement over time - it will also drive positive developments in AFC controls by helping to understand better whether those controls are working to actively reduce crime and illicit funds flowing through the financial services ecosystem. 

So what are we doing about this at FINTRAIL to ensure our clients adjust to the shift in focus? Our immediate response is to embed ‘effectiveness’ into all of our service offerings in 2021 from advisory to assurance; our consultancy teams are putting it at the heart of everything they do for our clients.

Secondly, FINTRAIL is now an investor in Cable.tech that is headed by the fantastic Natasha Vernier and Katie Savitz who both bring great pedigrees from the likes of Monzo and Square. Cable is focused on finding a technical solution to the challenge of AFC effectiveness. We are super excited by what the team there is building and are sure as 2021 progresses they will be taking the industry by storm. 

Increasing specialisation in AFC Compliance

A few years ago and anecdotally at FINTRAIL, we noticed a shift from quite siloed AFC teams with specific areas of focus across the different crime types (e.g. Head of Fraud), to a more homogenous AFC team structure with experts in a number of areas working together and collaborating. A particularly notable change in some organisations was the inclusion of Fraud teams into wider AFC compliance teams, where Fraud had sometimes more traditionally been placed alongside operations or in security and cyber security teams.  This flatter approach was especially popular in newly established AFC teams in startups and FinTechs. 

Our prediction for 2021 is that we are going to see an increasing specialisation of AFC compliance professionals in the product areas that they oversee and risk manage. For example, Fintech AFC compliance officers might well be broken down further into payments AFC specialists, Foreign Exchange (FX) AFC specialists and Banking as a Service (BaaS) AFC specialists. These specialist product skills will help AFC officers really pinpoint the risks their firm’s products are facing and thereby design more nuanced controls to manage those risks.

As such, it seems increasingly likely that these skills will be required by FinTech firms when recruiting and that candidates coming from more generalist backgrounds will need to demonstrate additional competencies in order to compete with the more specialist compliance officers out there. 

We have responded to this development and the growing, critical need for certified qualification in the FinTech industry by partnering with ACAMS to offer the Certified AML FinTech Compliance Associate (CAFCA) qualification and examination. This sets a new standard for the global FinTech industry and brings credibility and parity to an industry that has historically faced questions about competence. As our colleague Kate Hotten put it “It's for FinTechs, but it's so much more: it explores how scale, inclusion, new financial models and technical skills impact how we work in AML. We really worked hard to make sure this wasn't the same old AML blah-blah.”

Wellbeing is critical

2020 gave us all time to reflect on what wellbeing really meant to us as individuals, and firms are starting to do more to ensure that their staff are engaged, resilient and are looking after their physical and mental health. Not only is doing so beneficial for the employees involved, but it also has proven and wide ranging benefits on productivity, employee retention and engagement, inter alia. Staff in AFC teams are no exception to this, and in these roles especially dealing with the negative sides of society that we see when we investigate some pretty horrendous crimes, wellbeing should be prioritised.  Further, the sometimes relentless pressure - whether it’s from criminals breaching your perimeter controls to the more generalised stress of working in a regulated industry - can take its toll, and mental health and wellbeing should be taken seriously. Plus, with crime continuing to increase during the pandemic, this focus has never been more needed. And, just because we are working remotely doesn’t mean that wellbeing can be discounted, in fact it’s just the opposite.

At FINTRAIL, we are proud to offer the services of app-based therapy provider, Spill to our colleagues, and are also looking forward to exploring some more bespoke options with Your Virtual Wellbeing Hub, a research-backed one-stop-shop for employers looking to introduce, add to, or kick-start their employee wellbeing offering. We hope that these efforts will make sure that our team’s wellbeing is central to our company ethos.

For the wider FinTech FinCrime Exchange (FFE) community, we are excited to be offering a series of free, donation-based yoga classes from March onwards to help our members disconnect from their day jobs and find that all important “me” time, making them even better crime fighters.

So, whether you are looking to hone your compliance skills, take some time out for yourself from a busy day or are looking at how to revitalize your compliance programme over the next year, we hope you’ve enjoyed reading this piece, and if you would like to contact us about any of the topics raised in this article, or about any other anti-financial crime compliance needs, please reach out at contact@fintrail.co.uk

Goodbye 2020: Highlights of the year from the Europe team

Regulatory Changes

Throughout 2020, the financial sector saw a number of changes - including regulatory change. Whilst the year had its fair share of bad press around the adoption of regulation, there were also a number of positives to come out of 2020.  The implementation of the Fifth Anti-Money Laundering Directive (5AMLD) at the start of the year and the newly updated UK National Risk Assessment were long awaited updates that will help to drive positive change within the financial sector and beyond.   

Fifth Anti-Money Laundering Directive 

The 5AMLD came into force on January 10th 2020. The directive brought a number of changes, which now applied to firms that were previously unregulated. The 5AMLD now covers cryptocurrency firms, high value dealers (anything over 10,000 euro), and estate agencies. In 2020, cryptocurrency firms started to bolster and refine their anti-financial crime frameworks  - a sure result of 5AMLD.  

UK National Risk Assessment

Towards the end of the year the UK released it’s 2020 National Risk Assessment - an update on the 2017 Risk Assessment. The changes (highlighted in our December 2020 RegCap) included a number of increased risk levels for some specific industries such as property and trust/company service providers. The assessment also included initial ratings of newly regulated sectors such as estate agents. No areas saw their risk levels lowered, either for money laundering or terrorist financing. 

FINTRAIL Projects: Europe

Whilst the year wasn’t quite as many had planned, we at FINTRAIL continued to work with our global client base to deliver the best of anti-financial crime consultancy. The year saw us work on a number of different projects, from risk assessments to creating due diligence policies. Two areas that increased in popularity this year were audits and training. 

Audits often get a bad reputation. They are a regulatory requirement and often seen as a burden. However, these can be extremely useful tools and help to shape and prioritise the year ahead for your anti-financial crime function. We conducted several audits in 2020, from a crypto firm’s first audit to working with a challenger bank who is well versed in the audit process. 

Firms have also looked to either increase their knowledge or change the way they are learning and conducting training. Despite the challenges of working from home, FINTRAIL delivered bespoke, specialist training - albeit from behind a screen. This appetite for training stretched across most companies with an increase in requests for training of more junior members of staff as well as the more senior compliance employees. RegTechs also requested training in 2020, to ensure their sales teams were attuned to the latest regulations; understand where their product fits into their potential clients’ lives; and were aware of the problems it solves. Alongside RegTech partners, our clients within the training space in 2020 included challenger banks, crypto firms and law enforcement agencies to name a few. This trend for increased training is likely to continue into 2021.

Another highlight of the year was conducting work in the investigations space. One particularly interesting project included a due diligence review and evaluation of the specific risks posed by a particularly high-risk client. FINTRAIL also assessed the current control measures in place and offered suggestions for enhancements to the financial crime control framework to mitigate the risk further. 

Part of  2020 was also spent leading a major transformation project within a bank's anti-financial crime function. This large scale project was great to work on, as it involved delivering various pieces of work from an enterprise wide risk assessment to customer due diligence policies, right the way through to the training programme for its employees. FINTRAIL successfully helped to shape a more effective compliance framework for the bank, entirely through remote delivery.  

Looking to the future

Entering into 2021, we look forward to working with our existing and any new clients that the year may bring. There are already early signs that the year could be an eventful one, with rapidly changing crypto regulation through to Brexit finally being realised. 2021 is sure to bring its challenges - and opportunities.

Snakes and Property Ladders

How is one of the most exciting moments in someone’s life also the most stressful? 

Passports. Bank statements. Proof of employment. Payslips. So many different documents provided to so many different people.

For most people buying a house, whether for the first time or finally finding your “forever home”, is meant to be one of the best moments in their lives. But this is often soured by several journeys to the estate agents/solicitors to prove you are who you say you are or by needing to send numerous personal documents by post. 

This blog looks at the documentation and due diligence behind house buying - and how it can be simplified whilst still mitigating the risks. At FINTRAIL, some of the team have been lucky enough to have bought a place within the last 12 months. We have all experienced the good, the bad and the ugly during the process but surprisingly not all in the same area. We are going to discuss the risks associated with property purchases, compare and contrast our journeys, look at how this market differs from FinTechs and gain insight from Thirdfort, a firm which specialises in providing identity verification and source of funds checks for lawyers in the property market. 

What are the risks?

Before we dive into the FINTRAIL team’s experience of property purchases, we should look into the risks associated with the property market. Laundering money through the purchase of property is often described as one of the oldest known ways to legitimise ill-gotten gains. As property purchases naturally involve high prices, it is an easy way to move large sums of criminal proceeds. Properties can also be used operationally in a criminal’s organisation - potentially as a way to generate legitimate income via rent or as a location for other illicit activity. Another risk to be aware of, which is highlighted in HMRC’s risk assessment for estate agency businesses, is the risk of overseas buyers, especially from higher-risk jurisdictions. Property purchases may be made with the proceeds of crimes committed in other jurisdictions, including but not limited to bribery and corruption and even sanctions evasion. Transparency International published a paper in 2015 which showed the extent of this risk: 40,725 London property titles were held by foreign companies of which 4.89% were held by companies incorporated in secrecy jurisdictions. 

As the risks faced by the parties in the property sector are being increasingly highlighted by numerous governmental and non-governmental organisations, it is not surprising that the property sector in the UK has come under scrutiny by both law enforcement and the supervisor under the Money Laundering Regulations, HMRC. Unexplained wealth orders (UWOs) are a type of court order used in the UK to compel the target to reveal the sources of their unexplained wealth. It uses the reverse onus principle, where the burden of proof shifts to the target. We have seen the majority of UWOs being issued to find out how multiple high-value properties had been financed, and in the most recent case saw nearly £10m of assets handed to the National Crime Agency. This shines a light on the need to understand the source of funds used to purchase a property and if this is in line with the individual’s profile. In 2019, HMRC fined Purplebricks for breaches concerning failures in having the correct policies, controls and procedures, conducting due diligence and timing of verification. This highlights the need for the sector to have the correct level of customer due diligence in place, which involves understanding and verifying who your customer is. 

Our Journeys 

Where is the technology? 

The first interesting observation is the lack of technology in most of our journeys. Lauren was lucky as her solicitors used an app for verification and a portal to update on progress. Being able to take a picture of your ID and upload a selfie is something we now come to expect in the FinTech space, which was replicated here. However, for Rachel and JP, the methods used to verify their identity, including certifying copies of documents or having to see someone face-to-face, were time consuming, costly and quite surprising given the online methods we know work very well in identifying and verifying individuals today.  At the time of JP’s purchase, the national lockdown was underway and COVID restrictions were in place for all businesses. To require face-to-face contact when businesses should have been operating as “COVID secure” does not seem logical, especially with the numerous contactless options that are available.  

Thirdfort have noted that the legal sector is embracing technology at an increasing rate, and certain developments mean that this trend is likely to continue apace. The HM Land Registry recently announced that they are now accepting digital signatures, and the Ministry of Justice temporarily accepted video witnessing of wills during this year’s lockdown. At the same time, law firms have had to digitalise their approach to client due diligence due to social distancing and lockdown restrictions, so it seems that the process of buying or selling a property is set to become more tech-focused. 

So what if the industry took more of a risk-based approach?

Using a risk-based approach is an expected element in a risk management framework. Within the conveyancing process, a risk-based approach could include collecting different levels of information and documentation for identity verification, varying the beneficial ownership threshold for verification, and collecting different levels of evidence for source of funds/wealth all in line with the risk of the customer. To help define that risk-based approach, a risk assessment should be conducted to identify the areas with the biggest risk exposure and tailor the procedures to mitigate those risks. HMRC recently published guidance to help estate and letting agents identify and understand where those risks could lie. 

In our cases, there appeared to be a lack of a risk-based approach for Lauren with her source of deposit checks from the solicitors.  A small percentage was kindly gifted by her mum, who was then asked to prove her source of funds with numerous bank statement requests. Given Lauren’s mum has been a working professional for a number of years and has accumulated savings over those years, the level of detail required for her to prove this seems excessive. This point is emphasised more when you look at JP’s source of funds check.  His proceeds came from the sale of another house, but this was not investigated in detail to ensure the funds did not come from another source. At FINTRAIL we encourage all our clients to treat their anti-financial crime checks as something more than a “tick box exercise”, which does not seem to be the case in relation to JPs SoF checks.

What next? 

Here are some key takeaways for the property market to consider:

• Conduct a risk assessment to ensure you identify and better understand the key financial crime risks you are facing. 

• Look out for red flags of suspicious activity, which may include:

  • Anonymous or difficult to identity owner 

  • Unusual or inconsistent income 

  • Over or under estimated property prices

• Take advantage of the technology out there to create a smoother customer journey while still mitigating risks.

• Apply a risk-based approach to your financial crime framework to ensure you are focussing your attention on the highest risk areas, especially when it comes to verifying source of funds.

• Apply more targeted client due diligence and enhanced due diligence to specific areas of risks identified, rather than applying the same standard measures across the board. This allows firms to mitigate the actual risk posed by the customer rather than just conducting a tick box exercise.

• Look out for HM Land Registries guidance on digital identity checking in conveyancing.

• In light of the Covid-19 pandemic, companies such as Thirdfort have shown the importance of individuals being able to complete their due diligence checks in the comfort of their own home. It is important to hit a comfortable ground between ensuring firms can verify clients and manage risk compliantly and taking some of the pain-points out of property transactions for the client.

If you’d like to learn more, please contact Lauren Vincent, Team Coordinator, or email us directly at: contact@fintrail.com.

FINTRAIL Monthly REG-CAP Nov 2020

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

November 2020

In November’s issue, we cover post-Brexit sanctions.

Other highlights include two important reports published by Europol.

What other regulations changes caught your eye in November?

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

FINTRAIL Book Club: Anti-racism

In October 2020, and to mark Black History Month, FINTRAIL ran a team book club dedicated to reading books authored by Black, Asian, Minority Ethnic and Inidigenous people and People of Colour (BAME and BIPOC). We did this to improve our understanding of racism and the issues faced by the BAME/BIPOC communities, as well as to facilitate an open discussion, ensuring that everyone in the team participated actively in a discussion about racism. We wanted to share how we set up the book club, our key takeaways and our next steps.

We devised a list of books by BAME and BIPOC authors, and asked each person in the team to pick one book to read. We asked a series of short, generic questions (what was the story, what did you learn, what challenged you about the book) and then all met (virtually of course in these COVID-19 times) and each ran through the book we’d read and answered the three general questions.  This meant everyone could share their individual take on the book they’d read and we got to learn about a wider range of books than if we’d simply picked one book for us all to read. The team at FINTRAIL offers a huge note of thanks to Meredith and Ishima for coordinating all of this.

We held a lively and engaging discussion, the main takeaway being that we all experienced an overwhelming feeling of shock and frankly horror at the injustices BAME and BIPOC individuals have faced on a continuous basis throughout history. We learned from Mikey’s reading of “In Black and White” [Alexandra Wilson] about the injustices faced by black criminal barristers in the UK, and how the mistreatment of black people in the legal profession - often mistaking them for defendants - negatively impacts how justice is served to our BAME populations in the UK. There is a horrible and unjust (pun fully intended) irony here. Meredith read “Indian Horse” [Richard Wagamese], centering on the author’s experiences as an Indigenous person in Canada of the residential care system. The practice of residential care for indigenous people was only disbanded in the 1960s in Canada, and it subjected indigenous children to religious cleansing, child labour and sexual abuse in many cases, turning on its head the notion that Canada has been sensitive in its handling of indigenous communities. 

We observed too that there were wild discrepancies between how much black history we had all covered at school; some colleagues had covered elements of black history in detail, whereas others hadn’t touched on anything specific.  For many of us, this discussion was one of the first opportunities we’d had (or taken) to discuss racism openly and learn about black history.  That all being said, and as Maya pointed out based on her reading of “Black and British” [David Olusoga], it became clear to us that we need to start teaching black history not as a history of black people in Britain, but as an integral part of the history of Britain. We lose important context if we do the former. As such, it seems critical that schools and educational institutions examine urgently how they are teaching history that fully encompasses the Black, Asian and Minority Ethnic/BIPOC experience. 

As regards other practical steps to be taken, we learned from James’s reading of “Why I’m No Longer Talking To White People About Race” [Reni Eddo-Lodge] that the need for black equality is not about inverting the power balance between black and white people, but rather rebalancing that power evenly. James noted - in a work-based example - that the notion therefore of hiring people solely on “merit” was no longer sustainable, and that to redress the imbalances caused by racism, more proactive hiring of BAME/BIPOC individuals is needed.  

Finally, we learned from a number of the books we read that white people have been conditioned not to talk about race, or deal with their privilege and that this has to change if we are to make inroads into the battle against racism. Therefore, a small, but important logistical observation stood out: running the book club the way we did - with each person reading and commenting on a different book -  facilitated a very open discussion.  In turn, this ensured that everyone participated and had to start that conversation about white privilege and Black, Asian and Minority Ethinc/BIPOC oppression with the group, and - most importantly - with themselves.

If you’d like to learn more, please contact Gemma Rogers, Co-Founder, or email us at: contact@fintrail.co.uk.

FINTRAIL Monthly REG-CAP Oct 2020

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

October 2020

In October’s issue, we cover FATF’s response to Weapons of Mass Destruction proliferation financing.

Other highlights include the INTERPOL-EUROPOL 8th cybercrime conference and the removal of Sudan from the US sanctions list.

What other regulations changes caught your eye in October?

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

Case Study: Digitisation Support

Designing Financial Crime Compliance Programme for Africa-Focused Digital Product

A case study of how FINTRAIL helped an international banking group launch a new digital product, by designing an innovative, tech-focused financial crime compliance programme.

See how FINTRAIL designed bespoke policies and procedures, processes for customer onboarding and ongoing monitoring, to ensure full regulatory compliance, effective risk mitigation, and great customer experience.

If you are interested in speaking to the FINTRAIL team about this or any other financial crime topic please get in touch with the team at: contact@fintrail.co.uk

COVID-19 and the rush to Digital Onboarding

By Jessica Cath (Senior Consultant, FINTRAIL)

In July 2020, FINTRAIL wrote about the hot topic of digital onboarding and how to use Compliance as an enabler to necessary digital transformation.  With much of the world living life from their sofas and managing their day-to-day financial needs from home, COVID-19 had kickstarted a rush for digital onboarding. 

Three months later, as we settle into the new normal, we have an opportunity to reflect on the potential risks of implementing new technologies in challenging circumstances, as well as the opportunity to refine the digital journey going forward.

Successful digital implementation in the long term depends on fully understanding the technology and the associated risks – and how these risks fit within your risk assessment and existing control frameworks.

FIRST IMPRESSIONS MATTER

A streamlined onboarding process is vital for both customers and firms. 

Onboarding is the first opportunity to showcase quality relationship management, build trust with new customers, and demonstrate both efficiency and technological prowess. Onboarding is also expensive and scattered with regulatory requirements, so it is vital for firms to get it right first time and in a short timeframe. 

Digital onboarding can offer solutions. Replacing or refining traditional and often paper-based onboarding channels can speed up the process, improve user experience, reduce costs and - if implemented correctly - enhance compliance with regulatory requirements.

COVID-19 AS AN ACCELERATOR

The arrival of COVID-19 meant that digital onboarding capabilities became a matter of priority. Lock down measures restricted face-to-face interactions and any paper-based onboarding was effectively halted. 

Today, despite the relaxation of restrictions, we still see fewer customers at physical locations and fewer face-to-face interactions. 

We have also seen more customers proactively choosing to use digital channels. Digital experiences during lock down have increased confidence in technology channels and most customers now expect fast, seamless and digital onboarding.

THE RISK OF RUSHING

Despite many benefits of digital onboarding, rushing into new technology can expose the firm to risks – particularly if new technology is implemented in haste.

Given the challenging circumstances of remote operations and the need to adopt technology at speed, these risks are heightened.

Network and data risks 

Risks to data and network security are particularly high. The pressure to maintain business continuity during COVID-19 may mean that compromises were made. New technology may have been implemented with quick-fix workarounds outside of the fundamental security principles. With limited time for comprehensive proof-of-concept testing or securing systems-by-design, new technology or its integration may have vulnerabilities and leave the firm exposed.

Financial crime risk 

Risk of exposure to financial crime is also high. COVID-19 has proven to be a fertile ground for fraud and cyber-enabled crime. Confusion, misinformation and fear make customers and firms more vulnerable to fraudsters. Any new onboarding technology must be properly configured to the firm’s specific client base in order to effectively mitigate new fraud risks. 

TIPS FOR SUCCESSFUL DIGITAL IMPLEMENTATION

To overcome these challenges, there are several considerations and top tips for successful digital implementation. Ideally these steps would be taken prior to implementation but also offer areas for reflection and refinement if the digital solution is already in place.

1. Understand the technology you are implementing

Fully understand the technology, data flows, security, configurations and the third-party provider themselves. 

The technology should be assessed and reviewed before implementation, with careful consideration given to secure, seamless integration. If workarounds are implemented to enable integration, these should be properly documented with appropriate debate, governance and oversight. Any workaround should also be reviewed periodically and re-assessed with a view to achieving a more permanent solution.

The third-party provider should also be assessed and subject to checks and screening in line with internal policy requirements. These checks should be documented with appropriate sign-off. If any of these checks were fast tracked during the lockdown period, now is the time to review and verify.

2. Ensure the technology fits within your risk appetite 

To ensure long-term success (not just to meet the needs of COVID-19 lock down), the technology should fit within the firm’s existing risk appetite and wider technology strategy. 

Despite the unprecedented circumstances, the Financial Conduct Authority (‘FCA’) made it clear that firms should not divert from established risk appetite. In their May 2020 publication on financial crime systems and controls, the FCA stated ‘firms should not seek to address operational issues by changing their risk appetite’. The functionality within any new onboarding solution should be reviewed in line with risk appetite, and any risk decisioning should be documented with appropriate governance and oversight. 

Any new digital solutions should also map against the firm’s digital journey in the long-term, instead of being implemented as a quick-fix solution. If there are discrepancies, these should be documented and addressed in the next iteration of the strategy to ensure alignment.

3. Update risk assessments and controls 

Similarly, risk assessments and control frameworks should be updated to reflect the use of new technology. 

Enterprise-wide risk assessments should be reviewed in light of COVID-19 and changing risk scenarios, as well as the implementation of digital solutions. New onboarding solutions may address some of the risk scenarios created by COVID-19 but can also create new risks that may need to be mitigated through other control measures.

For instance, new controls may need to be added to test the platform itself. As part of a digital onboarding solution, a new screening tool may have been integrated for faster sanctions, PEPs and adverse media screening of new customers. The firm must periodically test the screening platform – to verify the outputs and ensure it continues to work as expected, in line with parameters set by the firm’s risk appetite.

4. Ensure proper integration with infrastructure and process

Finally, to get the best out of new digital solutions in the long term, ensure it is fully integrated with both current infrastructure and streamlined processes.

Fully streamlined integration with existing infrastructure often requires comprehensive proof-of-concept testing. With limited time for testing during the COVID-19 lock down period, there may now be opportunities for refinement – both from an operational and security standpoint.

Firms should also take time to review operational processes sitting alongside the use of onboarding technology, to prevent duplication of process steps or error. New digital onboarding solutions offer opportunities for speed and efficiency, but only if old processes are adjusted and refined.

KEY TAKEAWAYS

• Digital onboarding solutions can benefit user experience, process streamlining and regulatory compliance, but can also expose the firm to further risks

• Successful implementation depends on fully understanding new technology and the associated risks - and how these sit within established risk appetite

• Existing risk assessments, control frameworks and processes should be updated to reflect the implementation of new digital solutions

• If any technology was implemented in haste for COVID-19 lockdown, now is the time to review and close any gaps!

If you are interested in speaking to the FINTRAIL team about this or any other financial crime topic please get in touch at: contact@fintrail.co.uk

When you should carry out ongoing Due Diligence and how to remediate gaps

The FINTRAIL and Jumio teams have been discussing why regulated businesses are expected to perform ongoing Due Diligence on clients, why it is important to remediate gaps identified, and the approach businesses should consider when performing this remediation.

In this report you will find examples of the different scenarios when you should consider refreshing your Due Diligence. It also highlights why it is important to remediate gaps and how you should seek to operationalise this process.

If you are interested in speaking to the FINTRAIL team about this or any other financial crime topic please get in touch with the team at: contact@fintrail.co.uk

FINTRAIL Monthly REG-CAP Sep 2020

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

September 2020

In September’s issue we cover FATF’s report identifying red flag indicators of money laundering and terrorist financing through the use of virtual assets.

Other highlights include new UK sanctions issued against Alexander Lukashenko and his associates following election rigging in Belarus, and some interesting new insights from Companies House on additional controls being brought in to help fight fraud and money laundering.

What other regulations changes caught your eye in September?

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

FinTech Approaches to Sanction Regimes

Announcing Expert Working Groups and Topic 1: Sanctions compliance

The FFE have kicked off a series of topical roundtable discussions among industry leaders, with the aim of connecting senior decision makers to discuss their own internal approaches to common challenges. These Expert Working Groups are under Chatham House Rule, with FINTRAIL acting as secretariat to facilitate discussion amongst experts. Thanks to RDC and RUSI, too, for providing expert insights alongside our FinTech experts.

Our first Expert Working Group focused on FinTech approaches to sanctions regimes, and gathered 18 sanctions experts from 8 different FinTech industries. After just two in-depth sessions, we were able to glean insight on best practices that we hope you find useful when benchmarking your own approach. 

As a sneak peek into some of those insights:

• Around 30% of the FinTechs we spoke with have a sanctions-specific risk assessment to support their risk-based approach, with several more working to create one.

• Unanimously, Expert Working Group participants are typically using conservative (or even very conservative) fuzzy matching thresholds ranging from 70%-85%, especially compared to industry averages closer to 85%-92%.  

• C-Suite and board members are increasingly expected to have sight of the Sanctions program and/or Sanctions-specific policies, vs. just the broader Compliance or Anti-Money Laundering program.

Check out the full report for more, and reach out to us at ffe_admin@fintrail.co.uk to share any insights of your own. And be sure to stay tuned for further Expert Working Group insights!

ON DEMAND: ComplyAdvantage Webinar - The Rise of Money Muling

*** Now available on demand ***

Due to rapidly changing global circumstances, high unemployment and uncertainty surrounded the future, money muling is tragically on the rise.

It is a crime that often disproportionately affects the most vulnerable and financially illiterate. Criminals involved in money muling often survive by tricking ‘clean’ individuals with no criminal history but who is ultimately responsible for educating and helping to prevent this insidious form of money laundering: individuals, banks, governments, regulators, social media platforms?

Join our expert panel including:

• Charles Delingpole, Founder & CEO, ComplyAdvantage

• Gemma Rogers, Co-Founder, FINTRAIL

• Tom Keatinge, Director, Centre for Financial Crime & Security Studies, RUSI

• Adam Hadley, Director, Tech Against Terrorism

In this thought-provoking webinar, the panel will be exploring:

• The role that social media platforms play in recruitment, advertisement, and propagation

• Why this issue deserves urgent and serious attention now

• What the financial services sector and the regulator is and should be doing to stop money muling

FINTRAIL Monthly REG-CAP Aug 2020

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

ON DEMAND: FINTRAIL- Elliptic Cryptoasset Compliance Virtual Bootcamp

***NOW AVAILABLE ON DEMAND***

For financial crime compliance professionals, cryptoassets are one of the hottest topics around. With regulators and global watchdogs like the Financial Action Task Force zeroing in on cryptoassets, any compliance team that isn’t educated on cryptoassets has a major blind spot. 

Cryptoassets are no longer a fringe financial technology: cryptoassets have a total market value of more than $250 million; bitcoin is among the top ten currencies globally in terms of the overall value of banknotes and coins in circulation; and over $500 billion flows between the banking sector and cryptoasset businesses annually. Cryptoassets are now a feature of the financial landscape. This exciting technology presents both compliance challenges and business opportunities for teams not only at cryptoasset businesses, but also for banks and FinTechs who can no longer ignore this burgeoning asset class.  

That’s why we’re partnering with the team at Elliptic to launch our first ever cryptoasset compliance virtual bootcamp. Originally launched on 30 June 2020, this online bootcamp is one we’ve designed to assist banks, FinTechs, and cryptoasset firms alike in identifying strategies for managing financial crime risks in this new phase of cryptoassets. We’ve launched this initiative to help compliance teams in their journey, and to educate and ensure the wider regulated sector understands the cryptoasset industry, how it may affect their business, and how best to practically address the risks while harnessing new opportunities. The bootcamp focuses on how your business can apply an effective risk based approach towards cryptoassets. This ensures the highest risks to your business are the focus of your compliance efforts, with less impactful risks sitting lower down the priority list. 

Led by FINTRAIL’s Danielle Jukes and Elliptic’s David Carlisle, and featuring guest speakers from around the financial crime compliance space, this complementary virtual bootcamp will include three engaging sessions across June and July. Each session will focus on the key pillars that we see as vital to a strong cryptoasset financial crime risk management framework. Content for the sessions will include: 

SESSION 1: CRYPTOASSET RISKS . . . WHAT’S YOUR APPETITE? 

Effective risk management starts by defining your risk appetite. If you are a cryptoasset business, have you articulated to your staff which risks you’re willing to accept? For example, are there certain countries that present especially high cryptoasset risks and with which you won’t do business? And if you are a FinTech or bank, have you clearly defined what degree of interaction your business will or won’t have with cryptoassets, and do your staff understand how to ensure adherence to that risk appetite? Until you’ve defined your risk appetite, you can’t expect your compliance team to develop an effective response. In this session, we’ll provide you with a conceptual framework for defining your cryptoasset risk appetite and using that foundation for effective risk management.

• Key takeaways: an understanding of how you can develop a risk appetite statement on crypto, and how it can affect your business, relevant examples of statements related to cryptoassets.

SESSION 2: ASSESSING AND GETTING TO GRIPS WITH THE FINCRIME RISKS:

Cryptoassets present specific financial crime risks and feature heavily in some typologies more than others. Understanding these risks and executing a crypto-specific risk assessment is critical to managing risk exposure, whether your platform offers cryptoasset services directly or not. If you are a cryptoasset business, do you understand which fincrime typologies present the highest risks to your platform? Do you offer privacy coins or other services that may present an elevated risk to your profile? If you are a FinTech or bank, while you may not offer cryptoasset services, do you understand crypto-specific typologies that may expose your business to indirect cryptoasset risks that are sometimes very difficult to detect? This session will equip you with the know-how you require to conduct an effective cryptoasset risk assessment for your business. 

• Key takeaways: an understanding of different types financial crime risks, how they present themselves within cryptoassets, and how your business can assess these risks.

SESSION 3: SYSTEMS AND CONTROLS - MANAGING YOUR CRYPTOASSET RISKS IN PRACTICE 

Managing cryptoasset risks requires access to systems and controls that can detect and protect against bespoke risks. Your compliance team should be working to solve the following questions:.

• For cryptoasset businesses, do you have access to these bespoke cryptoasset monitoring tools tools, and are they configured appropriately to your business needs? 

• For banks and fintechs, are you able to detect and assess risks related to counterparties who may be dealing in cryptoassets? Solutions exist that can enable you to do so, but they require expertise your business may not possess. 

• Filing SARs and undertaking reporting obligations related to cryptoassets can present specific challenges. Are you equipped to navigate these challenges? 

• Key takeaways: an understanding of what systems and controls are out there, and how they can fit into your wider anti-financial crime framework.

This bootcamp will help your compliance team work through these and other questions, and in doing so, will empower you to execute on a vital component of your financial crime risk management framework. If these three pillars are executed effectively, then your compliance team can confidently tackle the risks associated with cryptoassets. 

You don’t want to miss out on this opportunity to learn from FINTRAIL and Elliptic’s experts in cryptoasset compliance.