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
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:
*WARNING - Tiger King Spoilers Ahead*
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.
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.
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.
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.
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.
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.
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.
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’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.
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.
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)!
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
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.
In this episode, FINTRAIL’s Greg Wlodarczyk, joins hosts Sam Sheen and Marie Lundberg on the Captivated Audience podcast.
Listen as they discuss the importance of technology and people for FinTechs, the FinTech FinCrime Exchange (FFE), how changes in consumer behaviour affect AI and transaction monitoring and the inside track on FINTRAIL’s upcoming survey results on the business continuity activities of the FinTech community.
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.”
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."
****You will need to have a subscription or sign up for a trial subscription to view the full article. ****
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.
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.
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
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.
From war to pandemic, there is always a class of profiteers seeking to take advantage of a country or world in crisis. Unsurprisingly, the behaviour has emerged once more in response to the escalating international outbreak of COVID-19. US cyber security firms and news agencies have repeatedly warned about the rise in coronavirus phishing scams, where emails purporting to be from trusted authorities like the Center for Disease Control and Prevention (CDC) and World Health Organization (WHO) are being sent to unsuspected victims, tempting them into downloading malware onto their devices. Scam cures, such as colloidal silver and essential oils, are also on the rise. The Federal Trade Commission (FTC) and Food and Drug Administration (FDA) have even issued warning letters to several companies, who may be found to have violated federal law for selling unapproved products using false claims.
Unfortunately for financial crime compliance professionals, coronavirus risks go far beyond old scams targeting new fears. The landscape and scale of financial crime compliance risks are fundamentally changing, and without sound risk management, we might find ourselves among other overwhelmed, underprepared industries in the face of a pandemic.
It’s Not Just Fraud
While fraud has understandably received the most immediate financial crime-focused coverage, this is not the only financial crime area that we should analyse for potential spikes.
For example, we could see spikes in certain types of money laundering activity. Look at money mules - who are often recruited online through fake social media employment or romance scams. As individuals lose their jobs or have to find work from home, the prospect of being able to earn funds quickly through moving money from one account to another may become even more attractive. Some sites are even directly recruiting money mules in the name of supporting coronavirus victims.
It’s not all bad, however! Cash-based activity is on the decline in countries hard hit by coronavirus, and potentially cash-based money laundering along with it. Major international terrorist groups, such as the Islamic State, are advising their fighters not to travel to Western countries undergoing severe outbreaks of coronavirus, which could impact terrorist financing flows.
The best thing for financial crime professionals to do is to spend time thinking about how the pandemic may impact the specific financial crime risks they face as a business. They can then adapt their controls accordingly, to best mitigate the evolving threat landscape.
Investigation and Enforcement
Investigations are beginning to stall in the face of coronavirus as well, hindering the ability to meaningfully prosecute complex, cross-border cases involving bribery and corruption, organised crime and sanctions evasion. As the pandemic spreads across the globe, with travel bans, home working and quarantines being used as containment measures, compliance officers and lawyers investigating bribery and corruption have been forced to delay meetings and interviews, which could allow cases to drag on and bad behaviour to continue to proliferate.
In addition to stalling investigations potentially allowing for compliance risks to slip through the cracks, law enforcement is also facing pressure to keep up with demand. Police in the US are now shifting gears to enforce coronavirus rules and in some areas, have been urged to avoid “unnecessary arrests” as this could only lead to the virus spreading. Law enforcement priorities are fundamentally shifting, and financial crime is unlikely to get the focus or resources it needs.
Compliance Ops
Particularly in FinTech hubs like New York City and San Francisco, the latter of which is under a shelter-in-place order, employees are having to work from home in order to keep the business running smoothly, and this includes BSA/AML compliance operations staff and analysts. While FinTech workplaces generally encourage more working from home and may have better controls in place to ensure data security, the hasty transition can still generate problems if not managed effectively.
While internal fraud is often viewed as less of a concern in small and medium sized FinTechs, given the close and collaborative nature of their teams, this risk should still be fully mitigated. More than half of all frauds committed against business are done so either internally or by an internal actor colluding with an external one. And this is something we have increasingly begun to see in the FinTech sector. We have personally experienced cases where FinTechs have had to engage in trying internal fraud investigations, or where staff have been contacted by organised crime groups asking them to engage in fraud.
Generally speaking though, the vast majority of internal staff are team members trying their best for the company. Front line team members need to be supported now more than ever in the work that they complete. Staff may fall ill, leaving others having to balance heavier workloads. Staff may not find it as easy reaching out for help evaluating a new alert. And responding to crises can also detract from other important financial crime tasks, like filing SARs (if this is the case, make sure to contact FinCEN). In-person training and support that staff need in order to thrive, excel and finish work on time may not be readily available. By taking steps to ensure regular team communication, health, wellbeing, and safety, as well as access to educational resources, firms can build out more resilient teams.
Recession?
Finally, we get to the elephant in the room: it’s difficult to find an economist that doesn’t think the coronavirus pandemic will bring the global economy into recession, especially as we seemed to be nearing one prior to the outbreak. With transportation and hospitality industries suffering major blows, and with outbreak hotspots like Italy already facing a delicate economic balance, we should start looking at what impacts a recession could have on financial crime levels now.
Data from the last global recession indicates that financial crime and crime generally can go up during a recession. The first 6 months of 2009 for example had the highest fraud rate observed to that point in KPMG’s Fraud Barometer, and 36% of senior executives reported to Kroll that they believed fraud risks had increased due to the recession.
One report from the World Economic Forum indicated that, for young people struggling to find employment during a recession, the arrest rate increases by 10.2%. The difficulties in pursuing legitimate employment make criminal enterprise more attractive; what’s worse - once involved in criminal activity, it can be very difficult for these individuals to leave, making the level of recession-rooted crime increase further.
When thinking about financial crime contingency planning in the face of coronavirus, we need to think even bigger than just the short term impacts and start evaluating what our response will be in the face of possible recession. This also includes considering what typologies may evolve or proliferate, such as benefit fraud as more people apply for unemployment.
What You Can Do
There is a lot of uncertainty out there in the face of coronavirus, and we will benefit as an industry by working collaboratively to tackle financial crime challenges as they occur. The below are just a few tips and tricks for how to tackle coronavirus as a financial crime threat:
Reconsider your BSA/AML risk assessment. Which inherent risks are more or less impactful in the face of coronavirus? Which controls might be weakened?
Evaluate whether your second line controls can provide the same level assurance in the current situation. For where external expertise is needed, work with digitally-focused consultancies who can easily support you remotely.
Check up on your internal fraud procedures, to ensure strong whistleblowing protocols are in place, as well as appropriate access rights and 4 eyes checks.
Increase staff engagement through financial crime catch ups, remote training and clear lines of communication.
Don’t stop contingency planning, and add a potential recession to the list of events you’re planning for.
We are working hard with the FinTech FinCrime Exchange community to learn more about what specific steps the international FinTech sector is taking in response to coronavirus as part of their contingency planning. Stay tuned for future insights.
If you have questions about how your business should proactively take on financial crime in the context of coronavirus, reach out to Megan Millard or Meredith Beeston.
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
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.
I co-founded FINTRAIL in 2016.
“My FINTRAIL highlight so far was realising that we had achieved gender parity among our leadership team. 💪”
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.”
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.”
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.’'
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.”
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.”
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.”
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.”
Zopa: Scandal in the Boardroom
Last week, UK peer-to-peer lending firm Zopa found itself in the news when board member Kapil Wadhawan was forced to resign following his arrest in India over money laundering allegations. Wadhawan, the chairman of Wadhawan Global Capital and the owner of a large property finance group in India, co-led a £32m investment in Zopa which secured him a seat on the company’s board. He was arrested by the Enforcement Directorate, an Indian government agency responsible for policing financial crime, in late January in connection with a money laundering probe.
This incident highlights the importance of knowing who you’re doing business with - not only employees, partners, and vendors but also investors. In the thrill of securing financing, it can be tempting not to scrutinise your potential backers too closely, but as the Zopa case shows this is a potentially risky area. This is the start of a long term partnership, so both sides need confidence in who they’re dealing with. “Investor due diligence” should cut both ways, and target companies should be prepared to conduct “know your investor” research. Investors with poor reputations can have a knock-on effect on portfolio companies’ credibility, and their ability to raise future funds. And in a worse case scenario, these companies could even find their investors or directors involved in criminal proceedings, as in the Zopa case, or discover that the investment consisted of illicit funds.
Doing your Homework: Reputational and Integrity Due Diligence
Reputational and integrity due diligence should form part of the wider due diligence process alongside financial, commercial and legal diligence, and is vital for understanding financial crime risks. It can be relatively straightforward to ascertain the track record and reputation of well-established investors, but for more niche investors, those based overseas, or new figures in the market, this may not be so straightforward.
The obvious questions for an investee to ask are whether the investors are well-established figures with a good track record and a logical interest in investing in the company in question. How long has their firm been incorporated, has it made successful investments in the past, and does it have discernible experience in the sector? Does it seem to be in good financial standing? Are there any indications the investors have been involved in any previous scandals or legal or regulatory issues? It’s also important to understand their modus operandi and if they have ever been involved in dubious or aggressive business practices, or disputes with partners, competitors or other investees. This may involve determining if they are the subject of any inquiries by regulators or law enforcement agencies which haven’t yet reached the stage of formal proceedings.
In addition to the above, there are further issues to consider for investors from overseas jurisdictions with lower standards of transparency and higher levels of financial crime. What is the source of funds - how did the investor initially make their money? In some countries, analysing this information may require understanding of the country and its history - for example, anyone who established their fortune in Russia and the former USSR in the privatisation programmes of the 1990s. In many countries, it will be important to understand political patronage - whether your investors have political influence or connections, whether this could have helped them make money illegally or unethically or to avoid legal actions, and whether their position may be threatened by changes to the current political regime.
Sources of Information
In practical terms, where can investees find the answers to these questions? They will likely start gathering information in-house through basic steps like online research - sources like the investor’s own website, news reports, and Google searches. Speaking to others in the marketplace will help provide a sense of the investor’s track record and general reputation. To ensure consistency and transparency, investees can implement an ‘investor due diligence’ process (a project which FINTRAIL is ideally placed to facilitate), which in many ways mirrors a customer onboarding process. It will allow the investee to make sound, defendable decisions by establishing a methodology to collect consistent information from defined sources, analyse it in line with clear criteria and parameters, and establish transparent escalation and decision-making processes.
In some cases, it will be advisable to seek expert help in conducting this due diligence research, especially if early red flags are identified or if there are discernible high-risk factors such as the investor’s main country of operations. Expert due diligence research will look at the online sources mentioned above plus specialist media databases, local and overseas litigation and corporate records, regulatory watch lists, foreign language media reports, and cached online materials. If required, researchers can also conduct enquiries with human sources operating in the relevant sector and country, to help explain the investor’s history, modus operandi, other business interests, perceived probity and general reputation. This is particularly useful in countries with undeveloped media landscapes, poor press freedom, or limited public records. Appropriate sources may include founders or employees of existing portfolio companies, other investors or business figures operating in the sector, journalists, and former partners or employees. Conducting successful enquiries requires an excellent network of contacts, as well as understanding the specificities of the investor’s operations, in terms of the sector, type of business, and jurisdiction.
FINTRAIL’s Experience
The FINTRAIL team has extensive experience in both designing due diligence processes and conducting reputational and integrity due diligence. We have lately finished building and implementing an investor due diligence process for a UK-based FinTech. We have also recently worked with a client to conduct research on a potential investor, in a case which showed clearly how important it is for growing FinTechs to identify the right partners. FINTRAIL investigated a venture capitalist from Russia looking to invest in a UK-based FinTech, using our expert country knowledge and language skills; searches in Russian, US and EU litigation and bankruptcy records, criminal records and regulatory agency checks; and adverse media research in English and Russian. This uncovered concerns about the investor’s source of wealth and modus operandi including political connections to the Kremlin, business interests in opaque jurisdictions held through apparent shell companies, and UK corporate interests which bore similarities to those of the Hajiyev family, the subject of the UK’s first Unexplained Wealth Order (UWO). These concerns ultimately led to the FinTech deciding not to accept the investment - a potential disappointment in the short term, but an important decision to head off major issues in the future.
Get in Touch
If you are interested in speaking to the FINTRAIL team about due diligence 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
Like everyone, the team at FINTRAIL are living for podcasts at the moment. Whether we are on our daily commute or grabbing a coffee we are tuning into our favourite shows. For those of you that are keen to explore some new FinTech/ FinCrime related podcasts - here are some of our recommendations:
FinTech Insider / Blockchain Insider
“I love the variety and quality of speakers and the relaxed, but informed style of both these podcasts which cover the most recent developments in the FinTech and Blockchain world. Living in Singapore, these shows provide me with the regular global update and industry expertise I need.”
This podcast by the anti-bribery business organisation TRACE International looks at examples of financial crime cases and typologies, and at what can be done to tackle them through interviews with experts in the field. The topics covered are really varied - regulatory developments and best practice, diverse crime types such as doping in sport or wildlife poaching, and major international scandals such as the Luanda Leaks and the Volkswagen emissions scandal. Having this broad scope and including interviews with such diverse practitioners throws up interesting perspectives and shows how many forms financial crime can take.
Caliphate and Conflicted
I’m pursuing an extremism and terrorism financing theme at the moment. Caliphate is a series following Rukmini Callimachi of the New York Times as she reports on the Islamic State and the fall of Mosul. You are hooked from the very beginning and the insights provided on the inner workings of ISIS are fascinating. And for even more incredible insider information, I recommend Conflicted by Aimen Dean, a former jihadist turned British double agent inside Al Qaeda. This podcast combines incredible first-hand insights with expert analysis, and breaks down the complexities of history, religion and politics of the Middle East and puts them in a global context.
The Missing Cryptoqueen by Jamie Bartlett
The pyra-ponzi scheme that shook the world. The ‘Bitcoin killer’ that through an elaborate social engineering scam destroyed thousands of families and swindled billions of dollars. We were extremely privileged to have Jamie Bartlett share his OneCoin investigation at FFECON19. And through the FFE community, it has been awesome to open doors for Jamie to take his investigation to the next level. Breaking News: there will be a Missing Crypto Queen TV series. Can’t wait for Jamie to share his progress at FFECON20!
Financial crime matters with Kieran Beer from ACAMS
This is my go to for all the latest insights on trending Financial Crime topics.
Get in touch to let us know what your favourite podcasts are- we are always keen to add to our ever-growing list. Happy listening.
In this episode, host Isabella Chase is joined by guests to discuss the most recent money laundering leaks, UK-linked financial crime cases, and the impact that Brexit will have on the financial crime landscape. To discuss the latest news and headlines, Isabella is joined by our very own Gemma Rogers and Nick Parfitt from Acuris Risk Intelligence. In the deep dive, Isabella discusses the UK’s Economic Crime Plan with CFCS Associate Fellow, Helena Wood.
You can access the full podcast here: The Suspicious Transaction Report and also catch up on previous episodes.
If you would like to discuss the topics in the podcast, or if you want to know more about FINTRAIL, please feel free to get in touch with one of our team or at contact@fintrail.co.uk.
At FINTRAIL, like many of the clients we work with, we like to be as transparent as possible about our plans, successes and failures. So with that in mind, Gemma and I wanted to write a quick summary of 2019 and give you a view on what we are planning for 2020.
Thanks to our amazing team, partners and clients we had a pretty awesome 2019! We worked with over 30+ different FinTech and financial institution clients across Europe, Asia, North America and Latin America.
Amongst other things, the FINTRAIL team have helped our clients build compliant FinTech products, transform legacy financial crime infrastructure, conducted audits and worked with leading technology, people and process to change how modern financial service providers can address the threat of financial crime.
Additionally, we have continued to invest in and grow the global FinTech FinCrime Exchange (FFE), we now have over 170+ FinTech firms big and small that have joined the fight against financial crime across the US, Europe and Asia.
As we continue to grow as a firm, we are of course going to see some challenges. Firstly, setting a cohesive international strategy is hard, especially as a small and very busy team. Bringing the US and Asia markets online brought significant challenges, some of which we had just not thought about. With so many ideas on what we could and can do, it can be difficult to curb our enthusiasm sometimes. I think it would be fair to say that 2019 was a year of learning on this topic but we have taken that onboard and are now accelerating in to 2020.
We built out our team significantly - clearly this is a brilliant problem to have - but we did have to think more carefully about the culture and structure of our team. Just throwing bodies at an opportunity is not the right answer but we really think we have made great progress in refining what the FINTRAIL organisation and culture looks like and this will continue to be a constant priority for us moving forward.
Finally, I think it would be fair to say that as co-founders, we learnt a lot about ourselves in 2019. We have put a lot of effort into FINTRAIL and it is sometimes hard to step back and empower your team to take that forward. We are super fortunate that we now have a team that believes in our mission and have the enthusiasm and capabilities to take that forward. As a team and individuals we are not going to get everything right the first time but we are committed to learning at every opportunity and we aim to make FINTRAIL one of the best places to work, doing super important work for the best clients in the world.
However, this is all history and we cannot take our eye off the ball. So 2020 is going to be an even bigger year for FINTRAIL our clients and community we support and and this is how we are going to do it:
Continue to invest in our consulting teams to bring our clients the best and most relevant expertise and support. In 2019 we grew our global team and launched our businesses in the US and Asia; we have seen a rapid growth in demand for what we do. Without the right people, culture and infrastructure we simply cannot do what we do.
In Asia, led by our local Managing Director Payal Patel, we are already working with some of the largest regional players to ensure they build robust anti-financial crime provisions into their products and business plans. Payal will be building out our regional offering and scale her team across the region over the course of 2020.
In the US, led by our local lead Megan Millard, we have been working with established global players to transform their vision of compliance and anti-financial crime as well as working with new and highly innovative businesses to ensure they start their journey in a secure and compliant fashion. There will be a big focus on the US market in 2020 as we continue to grow the business there.
In Europe, led by our local Managing Director James Nurse, we have been supporting clients big and small through their compliance and anti-financial crime journey. This shows no sign of slowing down and we will be bringing our specialist skills to new markets in the region and continuing to grow the team out to cover the different European jurisdictions.
Data, Data, Data - there is no question that the fight against globally connected financial crime requires us to take a connected, community and data driven approach to have any meaningful impact. Over the last 3.5 years through the FFE we have seen the power of connecting people and sharing insight.
We have been exploring what FINTRAIL and our FFE community can bring to this challenge and we think we have a way forward.
We have now agreed a partnership with one of the leading global RegTech providers to start connecting our global community in that fight through the development of real-time threat data sharing. Gasps I hear, what about data privacy? Well this is not going to be some half-baked attempt to deliver data sharing. FINTRAIL and our partner are doing this properly - we have an existing community of motivated and technically savvy FFE members who are proactively asking for this, we can leverage our connections with global regulators, law enforcement and wider privacy community to get this right. Combine that with leading technology and world-class technical expertise and we have a solid combination.
Are we going to solve it overnight, absolutely not but It is going to be a key priority for us and the FFE community over 2020 and coming years. More specific details will follow on this topic in the coming weeks.
Continue to grow the community. The FFE is unique. It is the only global FinTech community dedicated to the fight against financial crime - and it is free. It is something that all of us at FINTRAIL are extremely proud of and we would not be able to make happen without the support of our partners at Regulatory Data Corps (RDC). We have big big plans for the FFE for 2020:
Meet-ups - in 2020 we will be hosting somewhere in the region of 20 meet-ups across the three regions and our aim is to make these even more relevant to the community. We will continue to strive to bring the global FinTech community together in a common cause and have a meaningful impact on the scourge of financial crime.
Podcast - yes, that’s right 2020 is the year we are launching our FFE podcast series and it looks like it will be a cracker. We are going to use this opportunity to dive into the topics that matter to members and learn more about the people and issues that impact our lives every day. The 12 part podcast series will feature all three FFE regions and we can't wait to see this mature for the FFE community and other interested parties that want to learn a bit more about it.
Expert Working Groups - we want the FFE to have a voice that has tangible impact. In 2020 we will be hosting a series of Expert Working Groups that will bring together Compliance and Anti-Financial Crime leaders from across the FinTech and financial services industry to dive deep into the key topics affecting the industry and come up with a common way forward. We will then use that platform to bring about change through our engagements with partners, regulators, law enforcement and customer communities.
Engagement with global law enforcement - in 2019 our team spent a significant amount of time engaging with law enforcement and regulatory enforcement bodies from around the world. This was about spreading the word about the FFE and educating on FinTech, but also the opportunities to collaborate effectively. We have built amazing relationships with partners such as the Metropolitan Police, City of London Police, HMRC, National Crime Agency, Europol, Department of Homeland Security, Federal Bureau of Investigation and many many others around the globe. This will continue into 2020 with even more vigour. The private sector has a critical role to play in supporting law enforcement efforts against criminality in all its forms and the FFE community is at the front of that effort.
FFECON - we had a ball at FFECON19 and based on the feedback we had after the event from all involved it is something that will be back for November 2020 (block your diaries). Our goal for 2020 is not necessarily to make this bigger for the sake of it, but rather focus on the quality of this event for our community and that is what we will achieve. In addition, we will be taking FFECON on the road for 2020, in either Asia or US market (TBC, so stay tuned) with the aim to make this forum accessible to the growing community and interested parties globally.
So there you have it, a transparent roadmap of what to expect from FINTRAIL and the FFE in 2020. It is going to be a blast but seriously hard work and I know the team at FINTRAIL are super focused on making this another year to remember. We can’t wait and on behalf of the team at FINTRAIL we wish everyone all the best for 2020!
If you would like to discuss the topics in this post, or if you want to know more about FINTRAIL and our 2020 plans, please feel free to get in touch with one of our team or at contact@fintrail.co.uk.
Access free resources designed to help strengthen your anti-financial crime controls.
We love to support projects that combat financial crime -
get in touch to find out more.
