Marcus Mølleskov

Sentencing of former Swedbank CEO Birgitte Bonnesen to 15 months in prison for gross fraud marks a significant moment for the banking industry. Cleared last year of making misleading statements about Swedbank’s #AML processes, the latest ruling by a higher Swedish appeal court comes as a surprise. It sends a strong message about accountability at the highest levels of leadership. While fines in the hundreds of millions can be absorbed by financial institutions, imprisoning a CEO for mismanaging #AML compliance escalates the stakes. This case puts a sharp focus on #IndividualAccountability, and it’s a wake-up call for leaders in banking and fintech to ensure that #AML, #FCC, and #AFC processes are watertight. Leadership responsibility has never been clearer. #Governance #Compliance #Leadership

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AML findings and more AML findings…

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Yesterday the Danish central bank asked Danish banks to develop risk management scenarios for a 'extreme but plausible' geopolitical scenarios, including a war in Asia over Taiwan. Small open economies have monetary policy challenges and risks quite different to large economies. They are unable to regulate capital flows in and out of their economies, and so currencies and economies are more vulnerable to global instability and shocks. Trump's announced cabinet picks are all pro-Israel, ensuring a continuation of widening war in West Asia, possibly direct war with Iran. The cabinet picks are all anti-China, ensuring escalation of hostilities and trade destabilisation in East Asia, possibly direct war with China and Russia involving Taiwan. Any hope we might have had that a Trump come back would live up to his words, "We will stop the wars", must be abandonned. There will be more war, wider war, possibly another World War. Yeah, that's probably something banks in Denmark and other small open economies should scenario in their risk management. Maybe a good idea for banks everywhere? So far . . . National Security Advisor - Mike Waltz Secretary of State - Marco Rubio Ambassador to UN - Elise Stefanik Chief of Staff - Susie Wiles Deputy Chief of Staff - Stephen Miller Homeland Security - Kristi Noem

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📢 In the wake of Nordea's court proceedings in Denmark (https://lnkd.in/e8p5_kJN) for potential breaches of the Anti-Money Laundering Act, comprehensive and proactive AML strategies are vital for financial institutions to avoid regulatory pitfalls. At Argus Pro, our commitment to strengthening AML processes is evident in our white paper, "Unseen Barriers Hindering Critical AML Implementation in UK Financial Services", published in Financial Regulation International in April 2023. This white paper offers deep insights into common compliance challenges and outlines practical solutions to overcome them. Argus Pro's proactive approach is a game-changer for Chief Compliance Officers, Heads of Regulatory Affairs, and MLROs. Our FinCrime HealthCheck™ is meticulously designed to pre-emptively identify and mitigate compliance weaknesses, ensuring your organisation is always a step ahead of regulatory scrutiny. This solution fortifies your transaction monitoring and KYC procedures, making them robust and capable of handling even the most complex financial crime threats. By integrating the strategies highlighted in our white paper, compliance professionals can enhance their organisation's AML frameworks, making them more resilient and effective. Our advisory services also provide tailored remediation plans, helping firms stay ahead of compliance challenges and avoid the significant fines and reputational damage that Nordea is currently experiencing. 🔗 Dive into our white paper and discover how Argus Pro can help your organisation build a stronger AML foundation: [Unseen Barriers Hindering Critical AML Implementation in UK Financial Services] (https://lnkd.in/e6PF7eeV). #Compliance #AML #FinancialCrime

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Finnish businesses that must comply with money laundering (ML) and terrorism financing (TF) laws, can now unlock the power of AML Accelerate, Arctic Intelligence's multi-award winning enterprise-wide risk assessment platform with our 14-day free trial. In Finland the laws and regulations concerning AML / CTF are laid out in the Act on Detecting and Preventing Money Laundering and Terrorist Financing (Laki rahanpesun ja terrorismin rahoittamisen estämisestä, abbreviated as the "AML Act"). The AML act aims to prevent money laundering and terrorism financing by establishing a comprehensive framework for enterprise-wide ML/TF risk assessments to identify and assess risks and AML/CTF Programs, to document appropriate and proportionate controls to mitigate and manage these risks. AML Accelerate is a cloud-based money laundering and terrorism financing business-wide risk assessment platform designed for small and medium-sized businesses in over 30 industry sectors and 60+ countries. Strengthen your defences against financial crime. Register now at https://hubs.la/Q02B_rw-0 #Regulations #ML #FinancialCrime #AML #AMLCompliance #RiskManagement

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📢📝 April 22, 2024. #PSD3 update. European Parliament (EP) adopted its position on PSD3 and Payment Services Regulation (PSR) drafts at first reading, with the following key points: ▶️ PSPs must verify unique identifiers and ensure strong customer authentication, compensating for losses due to inadequate fraud prevention. ▶️ Customers can control their personal data usage and opt out of data sharing. ▶️ Customers must receive clear information about all charges, including currency conversions and fees, before a payment transaction. ▶️ Cash access should improve with potential exemptions rules for retail shops and lighter standards for certain ATMs. ▶️ New players can enter the EU's internet payment sector with authorization, enabling credit card-free online shopping. New rules will standardize conditions EU-wide, focusing on liability, security, and data protection. 🤷‍♂️ The So What? ✅ EP closed the first reading on legislation, with follow-up by the new EP after the June European elections. ✅ PSPs should monitor further readings to understand the potential shifts in regulations as well as opening of new business opportunities. 📩 Do you have any questions? Feel free to ask in DMs :) #AdamanoConsulting #PSD3 | #Fraud | #compliance | #payments

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🇩🇰 Denmark has indicted Nordea, the largest bank in the Nordic region, for violations of the country's #antimoneylaundering laws that occurred between 2012 and 2015. According to Danish police, the Special Crime Unit (NSK) believes that Nordea failed to adequately #investigate transactions by Russian customers and ignored warnings regarding #transactions involving currency exchange offices in Copenhagen. The NSK stated that there is insufficient evidence to bring charges against individual persons in this case, which involves transactions exceeding 26 billion Danish crowns (approximately $3.77 billion). The investigation into Nordea's anti-#moneylaundering controls began in 2016, and the bank has set aside provisions for expected fines. Nordea has expressed disagreement with the charges and the legal assessment, asserting that it has taken appropriate measures to address weaknesses in its anti-money laundering processes and procedures. This case highlights the importance of compliance measures in banks and the consequences of lapses in #antimoneylaunderingcontrols. https://lnkd.in/eB5bsNmk

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Former Swedbank CEO Bonnesen sentenced to prison in money laundering case A Swedish appeals court found former Swedbank CEO Birgitte Bonnesen guilty of gross fraud for misleading statements regarding anti-money laundering efforts in Estonia during her tenure. She was sentenced to 15 months in prison. The conviction stemmed from two 2018 media interviews where Bonnesen allegedly downplayed the severity of money-laundering issues in Swedbank's Estonian branch. Although she was acquitted of six other charges, this ruling partially overturned a 2023 district court verdict that had cleared her of all charges. Bonnesen plans to appeal the decision. The fear of getting caught may discourage fraud, but it’s not enough on its own. Preventing fraud effectively requires a well-structured system of checks and balances, along with immediate and serious penalties for offenders. Without meaningful consequences, fraud can be seen as a calculated risk worth taking. The question of whether a 15-month prison sentence is enough to deter future fraud remains open to debate. While it sends a clear message, its impact as a deterrent may depend on factors such as the severity of the crime, how the sentence is perceived by the public, and the unique circumstances of the case. It's also important to consider how the sentence influences the financial industry and public confidence in institutions. This case signifies the importance of transparency and accountability for bank executives in preventing money laundering. #compliance #financialcrime #AML #Swedbank #fraud https://lnkd.in/eu35yBPm

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Are your KYC and AML practices aligned with evolving regulatory norms? Dive deep into financial crime prevention strategies in our upcoming webinar👇   Join us on Wednesday, 19th of June at 1 PM CET, and gain new insights on mitigating risks and elevating compliance standards within your organization.    Together with experts from Compliance Champs, you'll be equipped with fresh perspectives to stay ahead of the curve: from deciphering regulatory expectations to leveraging advanced technologies. 📅: Wednesday, June 19th 🕐: 1 PM CET 🗣️: Peter Engering, James Schlegel, CAMS, James Tucker   Sign up here: https://lnkd.in/dnPbZbdH #webinar #kyc #aml #finance #strategy emagine

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Due Diligence on High-risk Customers When the Danish Financial Supervisory Authority conducted a thematic inspection in 2024 to evaluate how Danish banks manage private banking customers, particularly in relation to AML measures, it showed: 💡 Key findings: - 57% of the reviewed cases lacked sufficient investigation into the origins of customers' funds. This gap highlights a significant weakness in the initial CDD processes. - For high-risk customers, 72% of the cases showed substantial deficiencies in documenting the sources of funds. This indicates that banks are not adequately scrutinizing and documenting transactions involving high-risk individuals. Check out this very clear summary with perspectives below, by my colleagues at Advisense in Denmark 👇🏼

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When a lack of humility leads to legal consequences. This is a tragic and fascinating case. Swedbank's former CEO has been sentenced to prison, partly due to an interview where she insisted that her bank maintained an ethical business model and robust anti-money laundering practices, claiming they were immune to the money laundering issues plaguing other Nordic banks. However, internal documents revealed she knew otherwise. Her statements misled the market. I've witnessed similar situations repeatedly. In most cases, the primary impact was a significant loss of trust, as executives defended themselves against allegations, claiming to uphold great values, a healthy culture, and ethical leadership, only to be found guilty of misconduct. This time, however, there are legal repercussions. I genuinely hope we can find a different path forward. Yes, companies must be mindful of liabilities. But I believe we would benefit greatly from adopting a more humble perspective, acknowledging our vulnerabilities. I address this issue in greater detail in the #YouCanCultureBook. ---- I think you might find this article interesting: Guido Palazzo, Alison Taylor, Michaela Ahlberg, Anna Romberg

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Automating AML 💡 Automation needs to be handled with care - it's not always the correct option (especially when it comes to AML compliance) However, I am really proud in the way we have developed our platform to be flexible in helping to streamline many different scenarios. For our users, but also for their customers. This morning I had a call with a customer who have identified a very specific, high volume, onboarding use case. The way the onboarding process works, type of customer and services provided all pointed towards the possibility of a more streamlined AML process. After spending an hour or so defining what the solution should look like, we were able to build a fully automated process in a couple of hours. It's of course integrated with their existing CRM software. ⚡ Automate the request for ID when a customer sign up. ⚡ Automate further verification checks, PEP and Sanction checks once information is received. ⚡ Initiate a client risk assessment for review and approval. The solution has guard rails in place to deal with refer results and potential matches to PEPs and Sanctions, but an estimated 70 - 80% of the onboarding process should be fully automated with minimal intervention. What's more is that the client's customers will be provided with a seamless onboarding journey, without any delays in the process. When I started with AML integrations a few years ago, this project would have: ⚡ Cost £1,000's (probably £10,000s) ⚡ Taken weeks, if not months, to deliver ⚡ Required lots of onboarding fees and separate AML related contracts with different providers With the Xama AML platform we changed all that. ⚡ Cost £0 ⚡ Completed in hours ⚡ Required a free Xama account and one phone call It goes without saying that I would love more firms to benefit, so if you have a process that needs streamlining - it might be only a phone call and a day away!

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🔍 Searching for a job or just looking to enhance your knowledge in different topics within financial crime compliance? 🔍 🚀 Have you considered taking one-to-one On-Demand training on any particular topic of your interest or where you feel a gap in your knowledge? 💼💰 Get in touch with me to discuss and schedule #OnDemand training and coaching in any of the following areas of high demand in the market; 🚀AML Risk Assessment 🚀Sanctions Risk Assessment 🚀Fraud Risk Assessment 🚀TBML Risk Assessment 🚀Correspondent Banking Risk Assessment 🚀Countering the funding of terrorism 🚀Anti-Bribery & Corruption 🚀Source of Wealth / Source of Funds 🚀PEP/Adverse Media Risk Assessment 🚀Know your customer (KYC) 🚀Customer Due Diligence 🚀Enhanced Due Diligence 🚀Financial Crime Investigations 🔒 In-Depth Knowledge: Gain a deep understanding of various financial crimes 💼 Industry Expertise: Learn from seasoned professional with extensive experience in financial crime prevention and regulatory compliance, ensuring you receive top-notch guidance and insights. 💡 Practical Strategies: Explore real-world case studies and practical exercises designed to enhance your ability to detect, prevent, and respond to financial crime incidents effectively. 👥 Interactive Learning: Engage in dynamic discussions, interactive simulations, and collaborative activities that foster a deeper understanding of financial crime compliance concepts. Drop me an email on [email protected] and we can discuss your needs and schedule a bespoke training session (or multiple sessions). We will issue certificate for each training session for your PDP and HR records. Note: These training sessions are delivered at cost and #NotFree

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On May 6th, the Swedish FSA announced it will carry out an analysis of sanctions screening systems in 20 banks. A few days before that, on April 24th, the EU adopted the Directive on the criminalization of EU sanctions violations. Directive will involve substantial changes to the enforcement of sanctions in the EU, by harmonising rules on the violation of EU sanctions and setting common definitions of criminal offences and penalties. Penalties for natural persons include 1-5 years of imprisonment, and legal persons a fine of up to 5% of worldwide turnover or EUR40 million, with optional additional criminal or non-criminal penalties. The directive also introduces reduced penalties for voluntary self-disclosure. Member States have until May 2025 to implement the Directive into national law. Read more about what´s new in international sanctions management in our newly published article below. Would you like to discuss how to establish assurance around your sanctions compliance program, the scope and effectiveness of your sanctions risk management, tools, efficacy of screening, data quality and investigations? Talk to us about: - Gap analyses against OFAC sanctions compliance program framework - Reviewing your sanctions risk exposure - Efficiency of controls - Methodology for handling of particular risks - The overall robustness of routine procedures - Training and organizational capabilities #sanctionsriskassessment #sanctionscomplianceprogram

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The Danish Financial Supervisory Authority (FSA) has provided guidance on determining when a #DeFi offering can be considered fully #decentralized and thus exempt from regulation under #MiCA. The methodology involves assessing whether no identifiable counterparty exists for users to contract with, typically due to the nature of the #software or its #management structure. Not only is this pretty stringent, but as a litmus test it could take a dragnet approach to capture ‘partially’ decentralized projects or projects still in transitional phases. What about Uniswap, which operates autonomously via #smartcontracts but has a dev team/governance token? Or Compound, where users supply/borrow assets through smart contracts and interest rates are algorithmically determined based on supply/demand – but the upgrades are managed by COMP token holders. Moreover, what does this mean for any project with governance tokens and any semblance of human interaction or engagement? To take it a step further, what happens when a project, such as MakerDAO decides to introduce autonomous agents into the mix, with AI-assisted governance like their End Game roadmap? Does this shift the scale in favour of an exemption? IMO, based on this logic the only way out is through – by disaggregating everything from the validator set to interactions at the App layer. Modular smart contract accounts, account abstraction, nonce management, minimum modular smart contract accounts. The fully Monty. In the meantime, we really want to avoid a market scenario where MiCA becomes a #regulation that reads like a directive. Eugenio Reggianini Adriana T. Mariana de la Roche Wills Dr. Max Bernt Dimitrios Psarrakis Tommaso Astazi Elizaveta Palaznik Inbar Preiss Hagen Weiss Maha Al-Saadi Peter Kerstens Filip Šaravanja Vlaho Hrdalo Anina Milanović Morana Vukić Perak

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🚨 AML News: Swedish Court Imprisons Ex-CEO of Swedbank for Misleading Statements on AML 🚨 Birgitte Bonnesen, Swedbank’s ex-CEO, has been sentenced to 15 months in prison. 𝗪𝗵𝘆? For making misleading statements about the bank's anti-money laundering operations that resulted in significant financial damage to shareholders. Here’s why this case matters: ↳ In 2017–2018, questions arose about Swedbank’s involvement in the Danske Bank money laundering scandal. Bonnesen reassured the public, stating there were no suspicious ties to Danske Bank. ↳ However, leaked information exposed suspicious clients funneling tens of billions through Swedbank, causing the bank’s stock to plummet. ↳ The court ruled that Bonnesen's misleading claims had caused substantial shareholder losses, which led to her conviction. ↳ Some of Swedbank’s clients were tied to high-profile scandals like the Russian Magnitsky fraud, making this case more significant. Source of information: OCCRP What makes this decision unprecedented is that it goes beyond just slapping banks with fines. It holds the individual CEO accountable for misleading statements and failures. This should serve as a significant alert to executives: 𝗣𝗲𝗿𝘀𝗼𝗻𝗮𝗹 𝗹𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 can be real, especially when it comes to public statements and transparency. This decision also highlights the importance of accurate public communication regarding anti-money laundering efforts => misleading statements can lead to legal consequences, not just reputational damage. What’s your opinion? Do you think CEOs should face personal liability for misleading statements that impact shareholders?

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Happy Monday all, fincrime headlines here: 1) Nordea accused of laundering 3.5bn USD for Russians between 2012 and 2015. The bank is accused of not investigating transactions and ignoring transaction warnings. Yahoo Finance https://lnkd.in/e9RYPwz3 2) In another example of criminals using cross-jurisdiction to make criminal investigations harder, Europol releases a paper on the challenges of mobile roaming and privacy, and how it slows down law enforcement data access. Criminals are using foreign SIMs from providers who don't agree to data sharing to conduct crime within the EU Europol PDF download https://lnkd.in/eUkYNABp 3) Aberdeen council staff member caught in employee fraud of 1m GBP. The tax team manager had permissions to issue tax rebates and edit payments and payees. The fraudster was on a salary of 35k GBP, and started embezzling to pay off his personal debts, then began stealing for holidays and phones BBC News https://lnkd.in/eDYVVv2F.

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𝗙𝗼𝗿𝗺𝗲𝗿 𝗦𝘄𝗲𝗱𝗯𝗮𝗻𝗸 𝗖𝗘𝗢 𝗕𝗼𝗻𝗻𝗲𝘀𝗲𝗻 𝘀𝗲𝗻𝘁𝗲𝗻𝗰𝗲𝗱 𝘁𝗼 𝗽𝗿𝗶𝘀𝗼𝗻 𝗳𝗼𝗿 𝗴𝗿𝗼𝘀𝘀 𝗳𝗿𝗮𝘂𝗱 A Swedish appeals court found Birgitte Bonnesen, former CEO of Swedbank, guilty of gross fraud. The conviction stems from misleading statements she made in interviews about anti-money laundering protocols in Estonia. Bonnesen was sentenced to 15 months in prison, overturning a previous acquittal. She plans to appeal the decision. While the fear of getting caught is a powerful deterrent against fraud, it's not enough. Effective fraud prevention requires a robust system of checks and balances, including swift and severe consequences for those who commit offenses. Without appropriate reprimands and sanctions, perpetrators may view fraud as a calculated risk worth taking. Whether a 15 month prison sentence is sufficient to deter reoccurrences of fraud is a matter of debate. While it sends a strong message, the ultimate deterrent effect may depend on various factors, including the severity of the fraud, the public perception of the sentence, and the specific circumstances of the case. Additionally, it's important to consider the broader impact of the sentence on the financial industry and the public's trust in institutions. This verdict underscores the importance of transparency and accountability for bank executives in preventing money laundering. The Fraud Fellas About Fraud Association of Certified Financial Crime Specialists - ACFCS #fraudfellas #fraud #acfcs #FraudPrevention #financialcrime #leadership #acfe #sustainability #law #lawenforcement #banking #governance #corporategovernance #regulators #compliance #sweden #nordics

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