General

Introduction Gatekeepers such as lawyers, accountants, real estate agents, and trust and company service providers (TCSPs) serve critical roles in facilitating legitimate financial and business transactions. However, their services are also exploited by criminals seeking to launder money, evade taxes, or finance illegal activities. Gatekeepers often have direct access to sensitive financial and legal information,…

Introduction The Risk-Based Approach (RBA) to Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance is fundamental to ensuring that gatekeeper professions such as lawyers, accountants, real estate agents and trust and company service providers (TCSPs) effectively mitigate money laundering and terrorism financing risks. Unlike rigid, one-size-fits-all frameworks, the RBA allows gatekeepers to focus their resources…

Introduction The financial crime landscape is evolving rapidly, driven by advancements in technology, changes in regulatory frameworks, and the growing sophistication of criminal networks. As we move into 2025, organisations must anticipate emerging trends and adapt their risk assessment frameworks to remain resilient. This blog post explores predictions for the future of financial crime risk…

Inadequate AML/CFT and Sanctions oversight exposes institutions to significant regulatory sanctions, reputational harm, and financial penalties.Risk-focused, actionable reporting is essential to helping Boards mitigate these threats and reinforce compliance To empower the Board to fulfill its oversight responsibilities, the AML/CFT and Sanctions Compliance Officer plays a critical role. By adopting a strategic approach to reporting,…

Independent reviews are a pillar of a strong, risk-based AML/CFT and Sanctions Compliance compliance program. They offer an impartial evaluation, pinpointing areas for improvement and ensuring a financial institution’s program effectively mitigates risks. However, if these reviews become checklist exercises focused on appearances rather than true effectiveness, they can create a dangerous illusion. This “form…

In this article, we’re focusing on what’s happening in the United States, particularly on various regulators’ increasing emphasis on risk management capabilities at major financial institutions. According to an unofficial source close to the Office of the Comptroller of the Currency, an internal report leaked to Bloomberg alleges that 11 of the 22 large banks…

Introduction Is your financial institution overlooking its greatest asset? In today’s competitive market, many companies undervalue the role of compliance. Financial services companies – whether banks, traditional MSBs, or innovative FinTechs – often become blinded by competition, enamoured with rapid growth, market size, and the allure of capturing market share and growing revenue. The financial…