How to conduct Customer Risk Profiling in the Gaming Industry

Regulations and Guidance

As part of the regulated sector within the UK, those in the gambling sector classified as remote or non-remote operators, are required to meet their obligations within the Money Laundering Regulations 2017. One of these requirements is to assess the level of risk a client may represent to the business and apply appropriate due diligence to match that risk. 

The Gambling Commission, in its industry guidance for the prevention of money laundering and combating the financing of terrorism under section 6.2, also highlights the need for operators to perform risk profiling against its customers.  

What does this mean practically?

Having a clear understanding of the inherent financial crime risk within the business is important. This is likely to be already done through a risk assessment process but when thinking about financial crime in the gambling sector the most prevalent risks are probably fraud or traditional money laundering. 

An example could look like:

Once the inherent financial crime risk is understood, it allows for better context of what risks the operator may be exposed to and subsequently what needs to be considered when assessing the risk of the customer. 

Consideration can then be made on the data points used which would initially be obtained through the registration process and any due diligence information collected. Whilst data points like country are still important, given that the key financial crime risk may be fraud, operators may wish to consider additional data points such as the email address, phone number or device to be included.

Now the data points have been established, in line with the inherent financial crime risks, an operator can consider how the scoring itself will work. Whilst you may think a complex risk profiling model is best, that may not be the case as it needs to be scalable, easily modifiable and explainable to the regulators.

Finally once the scoring is complete, ensuring you map the output to your due diligence process is the final step. This will enable an operator to offer a lower friction process for lower risk customers whilst still being able to identify higher risk customers allowing the application of enhanced due diligence. 

Dynamic Model

The profiling of an operator’s customers shouldn’t stop at onboarding though. In order to operate an effective customer risk profiling model which meets the regulatory requirements, mitigates the risk of financial crime and protects customers from harm from a responsible gambling perspective, operators should ensure it is dynamic. This means that rather than just using the data collected at onboarding to assess the customers risk, operators should use data collected from how the customer interacts with the product and also any additional due diligence obtained.  

Responsible Gambling

It is no surprise that some of the more recent fines coming from the Gambling Commission relate to operators failure to protect its customers from a responsible gambling perspective alongside failures to have appropriate controls to guard against money laundering.

In May the Gambling Commission published tighter measures to be implemented by operators, as part of their COVID-19 response, to protect their customers during lockdown. These measures include various points on assessing their clients:

• Review thresholds and triggers for new customers to reflect the operator’s lack of knowledge of that individual’s play and spend patterns

• Conduct affordability assessments for individuals picked up by existing or new thresholds and triggers which indicate consumers experiencing harm - limiting or blocking further play until those checks have been concluded and supporting evidence obtained, and;

• Implement processes that ensure the continual monitoring of their customer base – identifying patterns of play, spend or behaviours have changed in recent weeks.

Responsible gambling has strong links to financial crime with various cases documented being linked to those who were using stolen funds to spend. This means that responsible gambling is an important risk factor to be included within any operator's customer risk profiling model alongside the traditional financial crime risks mentioned above. Data points for consideration could be methods of payment, deposits and behavioural patterns.

If operator’s continue to ineffectively implement custom risk assessment models, and choose to not include a responsible gambling aspect, we can only expect more fines to be issued in the near future for both responsible gambling and money laundering failures.

How to approach creating a new customer risk assessment model

Here are FINTRAIL and TruNarrative’s key takeaways when considering a customer risk profiling model:

• Understand the inherent risk your customers represent to the business

• Ensure you select the correct data points unique to your clients and product offering

• Make sure the risk profiling is dynamic and doesn’t just stop once the customer is onboarded

• Consider the inclusion of responsible gambling within your customer risk profiling 

• Marry your due diligence process to your customer risk profiling

• Take into consideration how you would implement your model using technology providers like TruNarrative to ensure if a players risk or behaviour changes, you get an instant alert and action

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

This article is also available via TruNarrative’s website.

How to use Compliance as an enabler in Digital Transformation

Digital transformation for onboarding is a hot topic at the moment, given that much of the world is currently living their life from their sofas and managing their day-to-day financial needs from home. Having worked on transformation projects before with traditional FI’s, alongside assisting various FinTechs in the creation of new digital offerings, we at FINTRAIL thought it would be a good opportunity to move the spotlight onto compliance, and fly the financial crime flag by discussing some of the common misconceptions.

Front end change is just the tip of the iceberg

The ‘tip of the iceberg’ cliche has never been more appropriate when it comes to describing common misconceptions towards digital transformation. The main message is that a good user experience isn’t solely dependent on a minimal field registration journey, and that there are other components that need to be considered which the customer can’t see. Getting these components implemented effectively are equally as important and the focal point is our good friend - ‘a risk-based approach’. Having a robust risk-based approach can be the key for a slick user experience and dictate your approach to CDD, custom screening and risk management, enabling you to target your controls on your highest risk areas.

Less is more

It would be logical to assume that the less information you collect from your customer the better, and that allowing a customer to sign up by just inserting an email and password will drive your Trustpilot reviews through the roof. Ignoring the fact that this probably doesn’t actually meet your ID&V requirements, we would like to suggest that less isn’t always more. By creating a shortened registration process you may well get more sign ups, but if you subsequently need to perform downstream due diligence to address gaps, you could be creating a poor user experience further down the line, perhaps even in a critical situation when dealing with a vulnerable customer whose account has been frozen and they need urgent access to funds.  We don’t necessarily mean your registration process should be 100 fields deep across 10 pages but there is certainly a happy medium. 

Business enabling Anti-Financial Crime (AFC)

A common misconception is that financial crime compliance can be the blocker when it comes to innovation in these projects. It probably comes as no surprise that we at FINTRAIL would offer a healthy challenge to those naysayers. 

So, you are 6 months into your digital transformation project, it’s all on JIRA (other platforms are available) or you have a lovely Gantt chart. You have lined up all your sprints and it suddenly occurs to you that you should speak to your compliance team. After 45 minutes debriefing your compliance team, they have a bunch of questions and recommendations before you can move the project forward, resulting in you putting a big red “Stuck” against it. While you may have translated this into a no, these recommendations do not necessarily mean no, and even if it is a no, is that really surprising considering you have only introduced them as stakeholders so late on? Obviously we are focusing on the negatives here to emphasise our point and the above is certainly not a reflection on most businesses’ these days.

Some of the most successful projects we have been part of are the ones where AFC stakeholders have been included as part of the journey rather than just at sign off. There is a new breed of financial crime professionals who want to be viewed as business enablers and able to offer a great user experience as much as the next product owner.

A RACI (responsible, accountable, consulted, informed) matrix is often used in project delivery to divvy up people’s roles. With that in mind your approach may have been previously to assign compliance a consulted duty, but we would encourage you to increase their involvement in order to reduce blockers downstream and increase compliant innovation.

Being a Compliance Champion

Equally it is not just the business that needs to take ownership of transformation, it can also be the fincrime function itself. Embracing change has never been more important in a digital enabled world and as fincrime professionals we should be just as excited by these new developments. Whether it is the implementation of a new due diligence process or screening programme, don’t be afraid to rip up the policy and start again. There is no reason why the financial crime team cannot be the driver for change.

Build, Buy or Both?

Like the ‘tip of the iceberg’, ‘build or buy’ is also becoming a bit of a cliche. What we do know is that you will likely need to partner with some technology providers in order to achieve your future state goals. Equally, even if you partner with someone, there will be an element of building that goes hand in hand. There are a variety of great providers available with a range of capabilities but we would like to reposition the ‘build or buy’ question. No single provider will solve all of your needs, and equally, to build everything in house isn’t logical when there are specialist systems available. This potentially means that the ‘build or buy’ question is a goose chase and in fact an amalgamation of the two is the best approach to adopt. 

Takeaways

Here are our top takeaways to be a compliance champion when it comes to digital transformation:

• User experience does not stop on the physical registration page; it continues throughout the customer lifecycle

• Less is not always more when it comes to identification programmes

• Treat your compliance/ fincrime team as business enablers, engaging them in discussions earlier

• Answer your build, buy or both question

• A risk-based approach marries itself perfectly with transformation projects

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

FINTRAIL- Elliptic Cryptoasset Compliance Virtual Bootcamp

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. Launching on June 30, 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. You will also be awarded a certificate of attendance after attending all three sessions. 

Active Anti-Racism in Anti-Financial Crime: Our Next Steps for Combatting Discrimination

At FINTRAIL, our US and global teams have been closely watching the swell of protests unfolding in response to the shocking deaths of George Floyd and Breonna Taylor - the latest victims of ongoing and unjustifiable police brutality against black people. However, racism isn’t just the existence of bad actors engaging in criminal acts of violence; police brutality emerges from systematic and deep-rooted racism that has infected justice systems in the US and around the world for centuries. And unfortunately, the anti-financial crime sector, integral for feeding information on suspected money launderers and terrorist financiers to police, has been complicit in this institutional racism. At FINTRAIL, we are constantly working to do more to promote diversity within our ranks and to support and learn from black voices. But we can do more as a firm to not just avoid racism but actively reject it, particularly through our work supporting anti-financial crime teams. Together, as consultants and as community leaders in the FinTech FinCrime Exchange (FFE), we can help make meaningful change to improve the treatment of black customers and to hold ourselves accountable when we get it wrong. 

1. We promise to help champion and support non-white perspectives within our own team and the teams we work with. Implicit biases exist not only in day-to-day anti-financial crime activity, but also in senior level decision-making. People can unfortunately be prone to ignoring or undermining opinions given by black people in the room - and this is even more so the case for black women. In the worst cases - the room may be entirely white, eliminating the chance for non-white voices and perspectives to influence decisions on financial crime. How else can we be held accountable and understand the impact of our processes and decisions across all areas of financial crime risk management without ensuring black people are involved in the work and have the space to make constructive challenges? Thus, as FINTRAIL, we will make sure that we use our privilege to ensure there is always diversity in the room and that we listen to any and all challenges to our approach, especially from black people.

2. We promise to work with clients to take extreme caution in the consideration of demographic factors when evaluating customer risk.  Firms building out their customer risk assessment (CRA) models may choose to include demographic factors, including nationality. While under very specific circumstances, demographics may be strongly correlated with risk (e.g. cheaply purchased nationalities), we will not advise or support the inclusion of demographic risk factors into a CRA methodology in a way that could unfairly lead to the application of enhanced due diligence (EDD) measures to a customer solely based on their racial, ethnic or socioeconomic background. In practice, this means strongly questioning whether such a factor is necessary in a CRA model in the first place and, if included, ensuring that only specific risks to the business are targeted and that there is no undue bias in the weighting of such a risk factor.

3. We promise to be aware of racial biases that may exist within ourselves and our clients when it comes to clearing and investigating screening or monitoring alerts. Even when demographic factors have not been included in the calculation of a customer’s risk, racial biases can still cloud our judgment when evaluating one customer’s financial activity versus another’s. It is well documented that people are prone to more negative perceptions of those with darker skin, often without even realizing they are doing it. This can have dangerous effects for a customer, leading to their account being frozen or offboarded and their activity being reported to police. To help mitigate implicit and explicit bias in alert clearing, we will seek to support internal and external anti-racism bias training in the context of alert clearance and will push for the provision of clear decision trees to help analysts more objectively work through potential suspicious activity.

4. We promise to do more to recognise and help mitigate the racial biases that can exist within European and American identity verification RegTech platforms. Within the US and Europe, we are really lucky to have a variety of robust identity verification tools to suggest to our clients that help automate the onboarding process. Innovative solutions allow for FinTechs to match customer selfies, live selfies or videos to a verified ID document - allowing them to onboard the customer within only a couple minutes. However, some solutions can struggle with non-white faces as their facial recognition technology hasn’t been adequately trained in correctly matching non-white faces to IDs. This can lead to serious negative consequences - non-white victims of identity fraud may have their documents stolen and used to open financial accounts without being spotted, or alternatively, genuine customers may be routed through a laborious manual review process simply because they aren’t white. We will work closely with FinTechs and RegTechs in the community to identify practical solutions to ensure that identity verification tools can more effectively verify non-white customers.

5. We promise to take more initiative to build out innovative onboarding solutions for non-standard non-face-to-face situations. Under some circumstances, customers may not have the typical documentation needed to onboard - they may not have a passport or driving licence, or they may have recently moved country and have no address history. The good news is that more and more regulators expect financial institutions to have onboarding processes in place for customers who may be unable to provide traditional documentation - though some regulators go farther than others in their guidance. The bad news is that, in the absence of meaningful guidance, firms may end up with extremely manual onboarding processes, which require robust sensitivity training for front-line staff and which can delay financial access for those most in need of it. Some firms may even inadvertently avoid establishing a written approach to non-standard identity verification cases. We will do more to work with clients to help them establish more innovative approaches to non-standard onboarding and ensure that the approach is well-documented and that necessary training has been given to the front-line.

By working with the community on these practical steps, we hope to help inspire greater change within anti-financial crime best practice. No one should have a worse banking experience or be treated as a criminal solely based on the color of their skin, and we are committed to actively fighting for an actively anti-racist approach to financial crime.

On Demand Webinar: How to Implement eKYC & Keep Online Customers Safe

The recent shift towards digitisation has pushed businesses to review their KYC processes, and implement new strategies to protect their customers online.

In this on demand webinar, Robert Evans Fintrail co-founder and Claire Galbois-Alcaix at Jumio will discuss:

- The impact of digitisation on businesses and their customers
- The latest risks and compliance challenges
- How to implement a successful eKYC
- Tech innovations that help organisations keep their customers engaged
- Changes to the regulatory landscape and the future of eKYC

As people spend more time online, they leave a digital trail of information that can be used against them if put in the wrong hands. The convergence of online and offline has opened up entire new pathways for fraudsters, money launderers, and identity thieves to assume another person’s identity.

KYC (Know Your Customer) refers to the process of verifying the identity of your customers, either before or during the time when they start doing business with your organisation. With eKYC, businesses are able to perform identity verification and due diligence electronically, but must ensure they have the correct end-to-end identity verification strategies in place.

Rob and Claire will share tips and best practices organisations can follow to simplify their eKYC.

Remote Delivery: NuBank Financial Crime Compliance Project

In the current climate the notion of ‘working from home’ has become the new norm. This means that some businesses have had to rapidly adapt how they work, how they deliver their products and services to their clients, and how they remain top of their game. Whilst FINTRAIL do have physical offices in London, Singapore, the US, we operate flexible working for our employees, and have also conducted fully remote projects in the past. We feel that these projects and our working set up has allowed us to quickly adapt to this new normal and we thought we would share some of our insights with the wider community. 

One of our most recent fully remote projects involved working with NuBank on a Financial Crime Compliance project. NuBank is a Latin American neobank and they have one of the largest customer bases in the region and sector, and in January 2020 confirmed they hit the 20 million customer target. NuBank was a completely new client for FINTRAIL, and also one of our largest projects where there would be no face-to-face, or in person element at all.

The project spanned three jurisdictions; Brazil, Mexico, and the UK. This involved assessing, and analysing regulation from Brazil and Mexico, as well as scheduling calls to accommodate for two quite different time zones! After the project had been completed, we had a feedback session with NuBank to discuss what worked, and maybe what didn’t, when conducting a remote project. NuBank was very pleased with our work. They commented that we were aligned with them as a business, and the project results were above and beyond what was expected. We are confident that our work can be delivered in a fully remote nature, and this project only helped to solidify that confidence.

Key learnings:

• Get the basics right. This may sound simple, but the client should be clear on the project timelines and deliverables. Having this understanding at the start and throughout helps to ease both sides of any unnecessary stress, and improves time management and control of the project. When a project involves no face-to-face aspect, all communication becomes much more scheduled, and therefore understanding the scope and nature of the project is key. This extends to us as FINTRAIL too, we always ensure that we understand a company and its products to the best of our ability when conducting a project.
  

• Communicate, communicate, communicate (with the relevant people). Ensuring that the correct people are involved in the conversation is very important, especially during a remote project. With often already packed diaries, no one wants to sit on a video call that they cannot contribute to, or that they are not needed for.  By inviting the correct and relevant stakeholders only to meetings where they are needed prevents video call fatigue within the project, helping for each conversation to be meaningful and for people to remain engaged. 
  

• Leverage technology.  Tools such as Slack can really help with interim communication between larger video meetings. Slack allowed for timely access to key pieces of information, and to lay the groundwork for more in depth meetings. It was also crucial to have this kind of communication due to multiple time zones. Emails felt a bit stiff and formal, and could get lost in a pile, whereas the Slack messages could be picked up whenever suited, and answered quickly and easily.

Get in Touch

If you are interested in speaking to the FINTRAIL team about the topics discussed here or how we are working remotely with clients globally today on all aspects of their financial crime programme, please feel free to get in touch with one of our team or at contact@fintrail.co.uk.

FINTRAIL joins Tide on the Jumio Webinar: Covid-19 Anti Financial Crime Best Practices

Gemma Rogers, Co Founder at FINTRAIL joined Rebecca Marriott and Matthew Tataryn of Tide and Sam Duggan of Jumio for a live panel discussion moderated by Claire Galbois-Alcaix. In the webinar they cover:

• The financial crime impact COVID-19 has had on financial services providers

• The main financial crime threat factors that businesses are having to adjust to

• How the FCA's latest recommendations can help businesses in the short term

FINTRAIL’s Digital Anti-Financial Crime (AFC) Support

As a tech first company we have always used technology to serve our clients in the best possible way. As the global financial service industry embraces new digital and virtual working practices, FINTRAIL is uniquely positioned to support global customers. We want to ensure that we continue to enable organisations to thrive while managing their financial crime risk and meeting their regulatory requirements. 

As such we have taken three of our offerings and fully digitised them to ensure that we are still delivering the same tailored approach and bespoke output without compromising on quality. Our products are designed to be outcomes-focused and immediately impactful. 

On any audit or health check booked between now and the end of July 2020, that is completed by the end of the year, we are offering a 5% discount. Additionally to play our part in the fight against Covid-19, we will donate a further 5% to the World Health Organisation (WHO) Covid-19 Response Fund.

Get in touch today to discuss this and how we are working remotely with clients globally today on all aspects of their financial crime programme, or find out more here:

Digital AFC Support

Into the Tigers Den

*WARNING - Tiger King Spoilers Ahead*

Hey all you cool cats and kittens,

Most people reading this have probably seen or at least heard of the hit Netflix show, Tiger King, with its outstanding viewership of 34.3 million within its first 10 days of release. At first glance, the docuseries looks to focus on the captivity of big cats in the US; however the involvement of Joe Exotic soon pivots the focus to his love-life, rivalry with the owner of a non-profit animal sanctuary, Carole Baskin, and ultimately to the murder-for-hire plot of said sanctuary owner for which Joe Exotic is currently serving 22 years in prison. A $1 million lawsuit with Carole Baskin’s Big Cat Rescue Group is also ongoing. 

Whilst watching the captivating series, we at FINTRAIL noticed a reoccuring theme outside of big cats and cowboy boots. Financial crime. Episode after episode, it became evident that owning a roadside zoo in America comes with its own ecosystem of problems and characters, lots of whom have had their fair share of interactions with the law. This gave us an idea - let's set up our own big cat park ourselves! In this blog post we use Tiger King as a reference point, and walk you through how to set up your own zoo step by step, and ensure that the zoo and your activities can stay clear of the law.  Of course, this isn’t actually our goal. We’re aiming here to highlight how easy it is to do this, and the grey areas in the current US system. We take a look at:

• The ease of obtaining a permit for a roadside zoo, making it a prime target for exploitation

• The complex ownership structure hinted at in the Tiger King that could be used to hide beneficial ownership

• How the trafficking of big cats can be used as part of a wider money laundering operation

Joe may seem exotic himself but some of the themes and activities highlighted on the show are a sad reality, and are an open door for criminal exploitation.

License to own big cats, but not buy or breed them. But obviously there are ways to get round this...

The first step of this process is to apply for a government permit which will allow you to own a roadside zoo to show off your cats. Luckily, in many states in the US this is easy to do. 

If you claim to be displaying the animals as an ‘exhibitor’, you can easily obtain a licence from the United States Department of Agriculture (USDA) for as little as $40. As a criminal looking to exploit any system available for financial gain, this is a prime opportunity to use a cash heavy business to launder profits through:

• purchasing exotic animals with funds gained illegally

• faking the sale of exotic animals to justify the transfer of funds

• inflating the number of visitors to account for the increase of funds on the accounts

• inflating construction costs for the park itself

• inflating costs of upkeep for the animals and park

When applying, not much is asked about the applicant; as long as you have a social security number, you are eligible to exhibit big cats. Multiple previous convictions? Not a problem. Jeff Lowe and Mario Tabraue had convictions, including jail time, but this did not raise any red flags when submitting their applications. Surely, in a trade such as exotic animals where there are easy ways to make illegal profit, deeper checks into applicants should be crucial. It seems like the USDA just want to check you can pay them, rather than recognising the risk that is created by this lax entry criteria. 

Joe who?

Whilst there is nothing illicit or illegal about changing your name, it can make tracing ownership and finding records and media related to a person more difficult than for someone who has had one, or maybe two, registered names. The first thing to note about Joe Exotic is the multitude of names which he goes by. In court documents he is often referenced by upwards of five different names. Joe has been married three times, and has changed his name each time, sometimes making a double-barrelled name. He also has his ‘stage name’ of Joe Exotic, which he uses in everyday life. Information such as previous names, or aliases that an individual goes by can be crucial when assessing what risk an individual may pose. For example, adverse media checks conducted on only one of Joe’s many names may yield very different results compared to a search on a different alias. 

Old zoo, new zoo

When trying to hide assets, or even evade taxes, you may consider shutting down an existing business, and opening a completely new and fresh one. All the assets of the old business can be moved to the new business, however they are now under a separate legal entity, and in the case of tax evasion that business is unlikely to have any taxable profits. 

In legal records from the case between Joe Exotic and Big Cat Rescue, we found some interesting narration around the creation of a ‘new zoo’, and dissolution of the ‘old zoo’. The G.W. Exotic Animal Memorial Foundation, referenced as the ‘old zoo’, was created in 1999 by Joe Exotic and his parents, Shirley and Francis Schreibvogel. Shortly after the lawsuit in 2013 involving Carole Baskin and the $1 million judgement, a request was made to the Oklahoma Secretary of State by John Finlay (the old zoo’s vice president/director, and Joe Exotic’s husband at the time), to request a reservation of the name “The Garold Wayne Interactive Zoological Foundation", and a day later The Garold Wayne Interactive Zoological Foundation (‘new zoo’) was incorporated. The incorporation of the new zoo was paid for using the funds of the old zoo, the old zoo was then dissolved, and within this dissolution assets including vendor accounts and the gift shop inventory were transferred to the new zoo. However, the new zoo did not assume any of the old zoo’s liabilities. 

On paper, the two companies are different. Different names, possibly different ownership/management hierarchy structures - however it is clear to see that these two companies are intended to do the same thing, benefit the same parties, and ultimately have been created to hide, disguise, and try to put assets out of reach. This is an age old trick, and not one unique to the big cat or roadside zoo industry. As a result, law enforcement and the courts are well aware of this tactic. The court case recognised the new company was just being used as a vehicle to move and hide assets, and ordered the newly created Garold Wayne Interactive Zoological Foundation to also be held accountable for the $1million judgement in the lawsuit. If you are trying to hide your assets, it would be wise not to try this while in the middle of a court case when you are already under scrutiny of the courts. 

Keeping it in the family, and under the radar

Ultimate beneficial ownership (UBO) is a hot topic at the moment, particularly in the UK, where it is a legal requirement for all companies to disclose their ultimate owners to the corporate registrar. However in the US the landscape is wildly different. No state currently requires a company to declare the UBO, meaning it is easy to disguise the true beneficiary of a company. There is even talk at the moment within the US of relaxing the rules further in light of COVID-19

Complex ownership structures can be exploited to hide assets, and conceal individuals’ investments and involvements in business ventures. Joe Exotic made use of this tactic, and is even heard within the docuseries saying proudly to the camera, “Look around! I don’t own anything!”  When we had a look at some of the court documents surrounding the Tiger King, Joe was indeed right. He didn’t appear to own any assets at the zoo, or the zoo itself. 

As mentioned in the previous section, the original GW Zoo was founded in 1999 by Joe, under his original name of Joe Schreibvogel, and his parents Shirley and Francis. It is quite clear from the show that the zoo is Joe’s, legally or otherwise; he makes all the decisions and it is his responsibility to run it day to day.

The Big Cat Rescue Group settlement agreement outlined the continued involvement of Shirley in the zoo’s finances, without her having much actual involvement in the zoo itself. On paper, Shirley was the landowner and leased the land to the GW Zoo; however the settlement stated that these were not ‘arm’s length’ leases, and instead were used to transfer funds and assets to Shirley, so that they would remain out of reach of the ongoing lawsuit against GW Zoo/Joe Exotic. 

The settlement also states the ownership status of many vehicles and trailers within the zoo, and surprise surprise, they are all owned or leased by Shirley. Once again, this is a ploy to move all of the assets out of Joe’s name, and therefore supposedly out of reach of the court case. 

Lions and tigers and bears, oh my!

Arguably the most important aspect of establishing a zoo is the animals. 

You may think that getting hold of exotic animals would be difficult, but in many states it is simpler to purchase a tiger than to adopt a puppy. The Endangered Species Act of 1973 makes it illegal to sell endangered wildlife interstate or through foreign commerce in the course of a commercial activity. However you can be exempt from this Act if you are a USDA licensee, which is relatively easy as shown at the beginning of this piece, or an accredited sanctuary.

If we look at how Joe Exotic accumulated more than 200 tigers within GW Zoo, this was primarily done through breeding at the zoo. To care for a tiger, the food cost alone is between $7,500 and $10,000 per year, therefore Joe was not able to keep the whole litter and would sell the cubs. With the price of a large cat ranging anywhere from $900 for a bobcat to $7500 for a tiger cub, you can see why this is an attractive business and why Joe Exotic sold 168 tigers between 2010 and 2018 (the below map shows the far-reaching transfers of tigers from GW Zoo). Before 2016, there were fewer restrictions on the sale of captive-bred tigers as they were not considered important to conservationists and therefore could be freely traded, making it easier to trade across state lines. 

As you can see from the above, the amount of money that passes through a roadside zoo can be extensive, and this isn’t even including the admission and tour fees - some establishments charge nearly $400 per person for a tour. 

Not only can a zoo be used to move funds from other illicit activities, but there is great opportunity to use the zoo to commit illegal acts:

• Purchasing or selling endangered wildlife in a banned state or without the appropriate licence 

• Trading wildlife that has been illegally obtained 

• Laundering cash through inflating prices of wildlife sales

• Storing illegal drugs, as allegedly done by Mario Tabraue, who appears in the docuseries, before his arrest in 1987. 

The purchasing, breeding or exhibiting of exotic wildlife without the appropriate licence is illegal and therefore makes these animals criminal property. Profits from the subsequent trade of these animals are therefore the proceeds of specified unlawful activities (SUA), and money laundering is added to the long list of crimes that can be committed by these zoos. 

So where do I sign up? 

Absolutely do not set up a roadside zoo. 

The opportunities to conduct financial crime from a roadside zoo are extensive. The process of constructing a zoo itself presents the perfect opportunity as you can deal with high amounts of invoices for builders/supplies and deal with cash intensive industries to move illicit money. The subsequent running of the zoo creates more opportunity from buying and selling exotic wildlife illegally, to moving illicit funds through the zoo with inflated ticket prices and upkeep of the park. And as with other business types, you can set up constantly changing complex ownership structures to hide your assets.

As we have shown throughout this analysis, things aren’t always as they seem. Something that from the outside may look like a legitimate business can be used in numerous illicit ways. For financial institutions that service corporate clients, it is vital to analyse the industry lists in the context of your product offering, jurisdictional coverage and client base and see if something that might generically pose a low risk of financial crime, could actually be used extensively for financial crime purposes.  Hopefully this article has given you some red flags to watch out for, such as unnecessarily complex ownership structures, repeated changes in ownership, multiple name changes or aliases, or historic involvement in lawsuits or criminal prosecutions.

Get in Touch

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 one of our team or at contact@fintrail.co.uk.

FINTRAIL on the Sibylline Podcast: No Lockdown Here – Covid & Financial Crime

FINTRAIL’s APAC MD, Payal Patel, joins Sibylline COO Tamara Makarenko and Samantha Sheen for a conversation about the impact COVID is having on financial crime.

Their discussion covers why financial crime is ‘surviving’ lockdown, new financial crime trends, the regulatory response, and how companies can safeguard themselves. The podcast ultimately outlines a few ‘Golden Rules’ of how we can build our resilience to this unfolding financial crime environment.

FINTRAIL on the Captivated Audience - Season 1, Episode 26

In this episode, FINTRAIL’s James Nurse, joins hosts Sam Sheen and Marie Lundberg on the Captivated Audience podcast.

In this episode James offers insights from recent FINTRAIL papers on Social Media and Financial Crime, and the iterative risk approach to pre and post pandemic working for FinTech.

Relationship Management During Covid-19

We don’t really do the whole cold-calling thing at FINTRAIL. We are all pretty personable and we love to get out and chat to industry peers, whether over a coffee or a cheeky glass of wine. This is our best and most powerful way of building strong relationships with the community. So when Covid-19 emerged and we were all put on lockdown, naturally this put a spanner in the works for us at FINTRAIL. Remaining open minded and not being afraid of taking on the difficult challenges, we knew we still had to reach out to our network.

However, after week three of lockdown, as it dawned on everyone that we were in this for the long haul, the community remained strong. We found the majority of people were more than happy to have a 10 minute phone call/video chat. I can only put this down to a severe and sudden withdrawal of human interaction and a realisation that this was a long term predicament.

Below is a light-hearted summary of the reality of the effects of the lockdown:

• No one has worn proper clothes for a while; changing out of yoga pants and hoodies to put on “real” clothes seems absurd now. Which ties in with point number 2..

• There is a general worry that no one will fit into their “real” clothes again as the daily step count has gone from 10,000 down to 100.

• Most people are binge watching Tiger King, except me who is binge watching Billions (in both cases, we’re classifying these shows as work-related “research”).

• A home workout was attempted 3 weeks ago, but you forget how loud the music is in a gym class; it blocks out certain noises. I could very clearly hear myself gasping for breath which was enough to put me off trying that again.

• I have found common ground with others, who like me, walk over to their fridge, open it, stare inside and sit back down again. We have a secret hope that a magical bar of chocolate (that we didn’t put in there) will appear. Leading onto number 5..

• As that magical chocolate bar didn’t appear, some resorted to eating their Easter eggs a week before Easter.

We are all experiencing the same thing in varying degrees; whether that be trying to homeschool two kids while working from home, having your dog barking in the background just as it’s your turn to speak on a conference call or needing a banner that pops up at the start of every VC call saying “this is not my house, don’t judge me on my parents’ decor”.

If you fancy a break and a random chat, feel free to contact us at FINTRAIL; after all we are all human. There’s a time for business and a time to be human (who knows, we might even manage to have a productive conversation and do both)!

How Social Media is used to Further Financial Crime - Part 2

Similarly to most 18-year-olds, “Carlos” is glued to his phone, constantly refreshing his social media feeds and scrolling through friends’ pictures. In contrast with many other teenagers though, Carlos’ uploaded photographs illustrate a level of opulence and a life of excess. Carlos and his friends are pictured holding wads of cash, draped in designer clothes, Rolex watches on their wrists, and driving around London in a Mercedes. This seems quite implausible for an individual who left school after GCSEs and is now a junior employee at a central London restaurant (1).

Is the use of social media helping to fuel this problem? The HM Inspectorate of Probation’s report, ‘The Work of Youth Offending Teams to Protect the Public’, have described social media platforms as the “catalyst for some of the most serious and violent crime offences” (2). This is of no surprise as there has been a generational shift, with youngsters now living in a progressive online world which some adults just cannot get to grips with.

In Part 1 of this series, FINTRAIL used four basic money-mule associated search terms to pre-identify social media accounts of interest and those assessed to be associated with potential mule activity. These search terms were “Legit money UK”, “Easy Money UK”, “Flip Money” and “Instant Cash UK”. This investigation now seeks to focus on the initial phase of money mule recruitment and how by disrupting this critical stage it can disrupt the rest of the money mule value chain. However, it is important to first understand the money mule life cycle  which looks like this:

Honing in on Step 1 i.e. contact over Social Media, FINTRAIL have identified a number of key indicators of which combined together likely indicate an attempt to lure someone into Money Muling; these fall into two categories, visuals and language.

Visuals: There are a combination of images used that show instant gratification; key features include cash, cars, watches and evidence that large sums have been transferred into bank accounts. Further to this, many of the pages had adverts in their “stories” asking people to DM them if they want to make money quickly and requested people with very specific bank accounts to get in touch.

Language: By doing a simple drag and drop of Facebook, Instagram and Twitter pages into a tag cloud generator, FINTRAIL identified the types of language used across all platforms; the more popular the word, the larger it appears. The language used on the accounts really highlighted three key areas; fraudsters would request a specific bank account whether Barclays, Lloyds etc, then offer free fast easy money and explain that this was only a DM or whatsapp message away.

High chance of money muling: The combination of these images linked with these words are likely to indicate and point to something unsavoury and potentially illicit. This combination of factors can be used by social platforms to limit the likelihood of false positives when monitoring behaviour on their platforms and if kept up to date with evolving typological information, would create a far more effective disruption to wholesale financial crime scams than the over reliance on the regulated financial sector, by which point the damage is already done and the act of money laundering has already occurred.

So What Next? 

For FINTRAIL our money-mule journey on the social media platforms ended with the phrases “DM me for more info” or “whatsapp me”. However, in reality we know that this is only the beginning. We know that from here, behind the scenes, bank details are exchanged and money transfers are being made. This is where law enforcement has a critical role to play, coordinated with social media platforms, so that more can be done upstream to reduce the impact and have far more effect, reducing harm across the value chain of money mule activity.

Instagram as well as Facebook, use a new AI system Deep Text to essentially deal with and counteract major issues such as cyber bullying as well as malicious posts and comments. If the Instagram algorithm detects or finds provoking content, it’s discarded immediately. This demonstrates that technology already exists that can have an enormous impact on how social media platforms are abused (3).

A robust disruption of Step 1 of the money-mule cycle that is facilitated by social platforms will have a significant downstream impact where the end result would likely amount to a positive reduction in;

• harm and exploitation of vulnerable people

• costs to law enforcement effort (investigating money-mule cases)

• the burden on the UK and global Suspicious Reporting Regimes

• the burden placed on those operating in the regulated financial service sector

Very clearly, this needs to be an industry wide coordinated effort with law enforcement at the forefront and social media platforms on board. During the fifth Europol Money Mule Action (EMMA 5) week, 3883 money mules were identified alongside 386 money mule recruiters; 228 of these were arrested. As a major catalyst of money muling recruitment, social media platforms should share the burden and play their part in the deterrence of money muling by utilising technology they already have.

Get in Touch
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 one of our team or at contact@fintrail.co.uk

(1) How teenage money mules funnel millions from online fraud

(2) Monitor social media of young offenders to prevent crime says watchdog

(3)  Instagram leverages AI and big data

Keep Calm and Keep Planning: Pandemic Planning for FinCrime

No business sector has been left unaffected by the outbreak of the coronavirus. The financial sector, including FinTechs, is no exception. In times like this, working together as a community is more important than ever.

This document collates examples of how COVID-19 has impacted the FinCrime operations of FinTech FinCrime Exchange (FFE) members and how the teams have responded as they pivot to almost exclusively remote operations, as well as presenting some best practice guidance for a business continuity plan (BCP) and remote anti-financial crime (AFC) compliance.

It looks at how international bodies, financial regulators and law enforcement agencies across the globe have responded so far to the ongoing coronavirus situation, highlighting specific areas FinTechs should focus their attention on. 

The document also discusses differences between traditional business continuity planning and pandemic planning which may present unique challenges to Fintechs management teams. Finally, in its annex, the document collates information on COVID-19 related scams divided into four categories: imposter, product scams, investment scams, and insider trading. 

This guidance is based on research conducted by FINTRAIL across the FFE community. This includes a survey sent to all global members, review of 31 responses, 15 follow-up interviews, and additional research and analysis conducted by FINTRAIL. The survey and interviews were conducted during the week commencing 16 March 2020.

With thanks to members of the FinTech FinCrime Exchange for sharing best practices.

EUROMONEY - Regulation: For AML, FinTech is both problem and answer

Set against a number of high profile money laundering scandals in the sector, FINTRAIL Co Founder, Robert Evans was interviewed by Dominic O’Neill, EUROMONEY, along with some key industry leaders to discuss AML and FinTech and how technology, particularly RegTech, can help support financial institutions in upholding their regulatory requirements in the global fight against financial crime.

Rob discussing the negative press around FinTech:

“Because of the online nature of the communities they serve, they can be vulnerable to pressure applied by legitimate customers with legitimate complaints and vulnerable to misinformation,” says Evans, discussing the neobanks. “Fraudsters have learnt that applying pressure via social media is a way to release funds that have been frozen for good reasons.”

VIXIO PaymentsCompliance - Payment Firms Scramble To Counter Corona Fraud As Spending Shifts

As warnings abound over the frauds and scams taking advantage of the coronavirus crisis, the flexibility of financial institutions to react and adapt to the emerging threat is being tested.

Gemma Rogers, Co Founder at FINTRAIL was interviewed by Douglas Clarke-Williams, VIXIO PaymentsCompliance about how criminals are using the Covid-19 situation to their advantage to carry out financial crime related activity. Gemma also discusses some of the measures and adaptation an anti-financial team should think about to counter it.

"As you get into the detection methodology, reading up and being aware of these scams, and being aware of how they will manifest, is key," she told VIXIO PaymentsCompliance. "Then you can start to tune your transaction monitoring rules to look for the behaviours which might indicate that a customer has been scammed - or perhaps, worst case scenario, that a customer is perpetrating one of these scams."

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How Social Media is used to Further Financial Crime - Part 1

Introduction

Facebook, Instagram and other social media platforms have created simple methods of association. This in itself is both social media’s greatest strength and greatest weakness. You can share friendships globally but those with nefarious intent also have the mechanisms to create connections and identify vulnerable individuals that can be exploited to further their criminal activity.

Over the course of one week (pre-Covid-19 crisis) and as a follow up to our last article on this topic “The Role of Social Media in Furthering Financial Crime”, FINTRAIL conducted research on three key social media platforms, to assess the exposure of the platforms to financial crime activity - specifically money muling. This exercise should be considered a basic benchmark of the problem; our analysis suggests the scale is significant and likely to be systemic to the way money mule networks operate. This is further emphasised when you consider all the available social platforms likely to be used and private/DM functionality that keeps much of the content private. 

Methodology

Research material was obtained through passive observation, some of the groups identified were joined but at no time was there any form of direct engagement. FINTRAIL used four basic money-mule associated search terms to pre-identify accounts of interest and those assessed to be associated with potential mule activity. These were then manually reviewed to assess the group activity.

For this benchmarking FINTRAIL focused on three platforms; Facebook, Twitter and Instagram. The below infographic depicts the findings. Note: there has been no formal network analysis done to identify any crossover between platforms.

Findings

Summary

Pre-Covid-19, many people were already anxious about their financial situation, making them vulnerable to exploitation by criminal gangs seeking to develop mule networks. Research completed by Barclays revealed 6 in 10 people (60%) of respondents were worried about their finances on a weekly basis. 

Since Covid-19 started to bite globally, significantly more people have become financially vulnerable with more people out of work and in dire need of money to cover living costs. These factors create the ideal conditions for criminal gangs to target the vulnerable and there is likely to be a significant increase in the number of people who fall into the trap of money muling.

We will be investigating further into this topic in Part 2 looking to provide some practical information that social media platforms (and others) could use to help in identifying and preventing this kind of activity.

If you have any comments or would like to discuss the issues in this post, or wider anti-financial crime topics, please feel free to get in touch with one of our team or at contact@fintrail.co.uk

Stop. Collaborate and Listen

In our latest thought leadership piece we explore the idea of collaboration. This joint piece between FINTRAIL/FFE and RDC demonstrates the vital role that collaboration plays. We discuss the impact it has on the global fight against financial crime whilst highlighting some of the current collaborative efforts within both the public and private sector to date, showing their effectiveness within the FinTech and Banking industries.

Our ultimate conclusion is that the dispersal of information to a variety of individuals closely involved in the fight against financial crime is essential to any successful AML initiative.

The Role of Social Media in Furthering Financial Crime

Content warning: discussion of topics linked to suicide and child exploitation

Recently in the UK we’ve seen the suicide of a reality TV presenter, and in March 2019, the father of Molly Russell urged the government to introduce regulation on social media platforms in response to his 14-year-old daughter taking her own life. She was found to have viewed content related to depression and suicide on Instagram before her death.  While neither of these tragic instances can be solely attributed to social media, many are discussing the arguably significant role that online media played in both cases.  

Following on from these instances, in early 2020 the government announced that Ofcom - the communications regulator - was to be given the power to fine social media companies in a bid to protect children from harmful online content. Ofcom will not only be able to fine companies that fail to remove illegal content - such as the promotion of terrorism or child pornography - but online platforms will also be required to stipulate what behaviour and content is acceptable on their sites, and enforce those rules consistently and transparently. 

Clearly, the priority for Ofcom and social media firms has to be removing the most immediately harmful content - that which promotes suicide and child exploitation being critical.  However, there is also an argument for Ofcom and the social media firms to ensure that other types of content are correctly classified as illegal and are therefore removed. The other types of content that we at FINTRAIL believed should be more heavily moderated and removed pertains to financial crime.  

From our consulting experience in the FinTech sector, we have seen a multitude of financial crime cases where the schemes start on social media. In fact many of the low level criminal activities are facilitated and can only be effective due to social media.  A few examples include:

• Promoting the sale of goods on social media platforms; victims agree to purchase the goods, transfer the money to an account (often in the scammer’s own name, using their real identity) and the goods never materialise.  These are also known as advanced fee fraud.

• Money launderers recruit people - and pay them for access to their bank accounts - via social media profiles.  The launderers use the access to the recruits’ accounts to wash the proceeds of crime. This is known as money muling, and is worryingly common, even among young people.  

• Scammers can further advertise purported investments schemes online, attracting potentially thousands of users and defrauding them of large sums of money, sometimes even their life savings.

Images from social media used to entice individuals into money muling and other get rich quick scams.

Even in isolation, the results of these scams and schemes are incredibly harmful to the individuals involved; in some cases causing them to be blacklisted from banks (for having perpetrated money laundering through their accounts in the case of money mules), or in others to lose significant amounts of money.  However, it is also important to recognise the wider harm that such behaviour has on the rest of society.

Firstly, not only do many of the fraud and laundering schemes detailed above connect back into wider organised crime, involving the predicate offences of illegal drugs sales, human trafficking, corruption, arms trafficking, kidnapping and extortion (inter alia), all of which have an enormous human cost; secondly, the estimated cost of financial crime to global economy is conservatively estimated at between USD 1.6 trillion and USD 2.2 trillion. A Global Financial Integrity report from 2017 underscores how transnational crime undermines economies, societies, and governments, particularly in developing countries, often preventing those who are most vulnerable from getting the support they need, ironically, increasing the chances that they too become embroiled in a life of crime.

So, it’s with these huge human, societal and economic costs in mind that Ofcom needs to work closely not only with the social media firms themselves, but also with financial services firms, financial services regulators and law enforcement to best determine what content should be categorised as illegal and harmful, and seek to include this in their regulatory scope.  

In the same way that financial services firms are heavily regulated - because of the harm the provision of their services can cause - social media firms should also be required to take more proactive steps to prevent, deter and detect illegal and harmful content pertaining to financial crime from appearing on their sites.  

Practical steps social media firms can take mimic those applied in the financial services sector, such as Knowing Your Customer (KYC) processes  - including identity verification such that they can more effectively block repeat offenders - and more intelligent activity (transaction) monitoring, such that they can proactively identify higher risk profiles that should be subject to enhanced monitoring. This doesn’t have to be an arduous process: the FinTech sector has demonstrated that frictionless processes can exist, whilst maintaining compliance and gathering an appropriate level of customer due diligence in the process.

Clearly, any of these processes will have to be implemented proportionately, particularly to ensure the continued freedom of expression and speech.  However, considering the harm that social media appears to be, if not causing then at least amplifying, spending time, effort and money combating these issues and working to ensure proportionality is key for the ongoing success and safe utilisation of social media platforms in today’s society.

Get in Touch
If you are interested in speaking to the FINTRAIL team about the topics discussed here or any other anti-financial crime topics in an increasingly digital FinTech world, please feel free to get in touch with one of our team or at contact@fintrail.co.uk

Celebrating International Women's Day at FINTRAIL

International Women's Day (8th March) is a global day celebrating the social, economic, cultural and political achievements of women. The day also marks a call to action for accelerating women's equality. At FINTRAIL we are committed to equality and wanted to join in celebrating the women that contribute to making FINTRAIL a great place to work.

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Gemma Rogers

I co-founded FINTRAIL in 2016.

“My FINTRAIL highlight so far was realising that we had achieved gender parity among our leadership team. 💪”

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Maya Braine

I’m the newest member of FINTRAIL, and joined the team two months ago.  

“I joined FINTRAIL because I wanted to work in a dynamic, growing team where I could challenge myself, take the initiative, and feel my contributions make a real difference.”

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Payal Patel

I have been part of the FINTRAIL team for almost a year.

“My plans for FINTRAIL Asia this year are to continue to work with the most innovative and exciting FinTech companies in the region and to expand the rapidly growing FFE network.”

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Lauren Vincent

 I have been part of the FINTRAIL team for 8 months.  

“The best part of my job is how much knowledge I am able to gain from my colleagues on a day to day basis.’'

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Danielle Jukes

I have been part of the FINTRAIL team for 4 months.

“If I had to sum up the FINTRAIL team I would say that we’re a diverse team and all share a passion for our work.”

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Meredith Beeston

I have been part of the FINTRAIL team for 2 and a half years.

“I chose to work in FinTech FinCrime because I wanted to work alongside a growing industry and help find innovative ways to use technology in the fight against financial crime.”

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Ishima Romain

I have been part of the FINTRAIL team for almost 3 years.

“The top 3 things I've learned during my time at FINTRAIL: Personal - a traditional background isn’t required to be part of FINTRAIL. Technical - many processes that businesses conduct independently, as they usually align to wider controls, should be done collectively. General - to be adaptable in this ever evolving disruptive industry.”

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Rachel Clark

I have been part of the FINTRAIL team for 6 months.

“This year I am most excited about hearing the new FFE Podcast which will give interesting insights into individuals experiences with FinCrime in the FinTech sector.”

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