Oliver Gordon MSc (F.ISRM)

FCA fines Metro Bank £16,675,200 for Financial Crime failings #FinancialCrime #AML #CyberResilience #DataSecurity This is another major fine for systems & control failings before the #ConsumerDuty. In this instance 'bad data' features strongly. The headline is "Between June 2016 and December 2020, Metro failed to have the right systems & controls to adequately monitor over 60m transactions, with a value of over £51 billion, for money laundering risks". DEMSA has recently refreshed Financial Crime training for SMFs and frontline staff at a proportionate level for debt management firms not subject to the MLRs. This followed a recent FCA consultation on their Financial Crime Guidance (FCG). One of the striking features of the Final Notice 2024 (12/11/2024) is lack of effective response from key governance forums where risk management committees had identified high risks. It was evident in the Thematic Reviews of the debt solution sector starting in 2014 and 2017 that the FCA had struggled with proportionality with smaller firms that don't have multiple lines of defense. What is critical is that governing functions of a firm have good oversight of the core activities of the firm, with one person designated (through Prescribed Responsibilities) for Financial Crime in terms of accountability. Many firms have a designated MLRO, but not an SMF17. In our sector, this often falls to the SMF16 - which is a required role. Many 'debt buyers' are reliant on the financial crime processes in place from an FCA-regulated 'debt seller'. This was picked up by Stuart Sykes in the Fraud strand of the Credit Connect UK Think Tank last week in the session Chris Warburton chaired. In November 2023, the FCA reminded firms to strengthen anti-fraud systems and to treat victims of fraud better. The victims were often #vulnerable. This may resonate with many firms now as 'deep dive' findings emerge from 2023 and earlier. The fair treatment of fraud and scam victims will undoubtedly fall under the umbrella of the #ConsumerDuty from open and closed books. https://lnkd.in/eyc3dDZ9 SM&CR and Financial Crime refresher training is available. Teaser link below. https://lnkd.in/ePy855Nx Chris Warburton Kevin Still Stuart Sykes Denise Crossley FCICM Neil Webb Rob Franklin Daniel Calcott Sharon Burt Bernie Phillips Ken Apter Simon Unsworth Nigel Bryant Joshua Hopkins Chris Thornton Dees Jamie Davies Debbie Gandy Kevin Prone Luke Cuthbertson Barry Hind Neil Reddin Alan Linter https://lnkd.in/e7xJ9gCR  

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Suspicious activity reports (SARs) are essential for combating complex threats from financial crime. But when it comes to the financial sector, standards of financial crime reporting must improve. We’ve created our top seven recommendations for enhancing your SARs 👇 https://lnkd.in/ebfE__85 #SuspiciousActivityReport #FinancialCrime #FinancialServices #Compliance

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🏦 The Wolfsberg Group, an association of twelve global banks that develops frameworks and guidance for managing financial crime risks, has had a busy couple of weeks. ⚖️ Last week, it announced its response to the UK’s HM Treasury consultation on improving the effectiveness of the Money Laundering Regulations 2017 (MLRs). 🔍 In its response, it called for making customer due diligence more proportionate and effective, and also for strengthening system coordination. 🚩 And today, the Wolfsberg Group also published a Statement on Monitoring for Suspicious Activity. The Group asserts that it does not believe the increasing volume of SARs/STRs is proportionately contributing to effective outcomes in the fight against financial crime. 🌐 As many of you know, the Basel-based association has a profound influence on the development of AML practices worldwide. For a deeper understanding of its role and impact, check out this article on our blog: 📗 Understanding the Wolfsberg Group's AML Principles: An Overview and Impact on Global Financial Compliance > https://lnkd.in/dffXfcnt #AML #FinancialCrime #AMLScreening #WolfsbergGroup

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An Enterprise-Wide Risk Assessment (EWRA) is at the heart of robust AML/CFT compliance, empowering organisations to identify and manage their vulnerabilities against money laundering and terrorist financing. But what does it take to build an effective EWRA? A well-structured EWRA is not just about compliance—it’s a proactive defence against financial crime. Here is the infographic providing insights into the key elements of an effective ML/TF risk assessment: #ML #TF #AML #AMLCFT #AntiMoneyLaundering #AMLCFT #AMLCompliance #Compliance #Risk #EWRA #FWRA #RiskAssessment https://lnkd.in/drCbD3cq

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The Financial Conduct Authority has published a speech by Andrea Bowe (Director of the Specialist Directorate) outlining next steps for tackling #fraud and #financialcrime. The speech notes: 👉 The importance of partnership and the role of the FCA in helping to reduce financial crime, working collaboratively on the Economic Crime Plan and the wider Fraud Strategy. 👉The fast-evolving nature of fraud typologies and the development of emerging technologies 👉A 2023 fraud tech sprint to test tactical cross agency collaboration within regulatory, intelligence and law enforcement agencies. 👉Working with industry, by providing more guidance on how to tackle financial crime and sharing information on threats identified. 👉The Home Office Global Fraud Summit communiqué setting out an agreed global framework to tackle fraud. 👉Working with international partners, including the International Organisation of Securities Commissions (IOSCO). 👉That technology is transforming cross-border fraud and money-laundering detection, with cyber and identity fraud increasing in scale, sophistication and impact, as artificial intelligence (#AI) becomes more widespread. Access the full speech here - https://pimfa.cc/MHpPu

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📢 We have updated our enterprise-wide risk assessment checklist 👇 This free resource is designed to help you identify and mitigate key financial crime risks, ensuring your organisation stays compliant and proactive. From money laundering to fraud, this checklist covers the critical areas to focus on in your risk assessment. 🔗 https://lnkd.in/ebred8H8 We hope you find it useful! #FinancialCrime #RiskAssessment #Compliance

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𝑯𝒐𝒘 𝒊𝒔 𝒚𝒐𝒖𝒓 𝒂𝒏𝒕𝒊-𝒎𝒐𝒏𝒆𝒚 𝒍𝒂𝒖𝒏𝒅𝒆𝒓𝒊𝒏𝒈 𝒄𝒐𝒏𝒕𝒓𝒐𝒍 𝒇𝒓𝒂𝒎𝒆𝒘𝒐𝒓𝒌 𝒔𝒕𝒂𝒄𝒌𝒊𝒏𝒈 𝒖𝒑? In a press release issued on 12th November 2024, the FCA have announced they are fining Metro Bank £16m for financial crime failings. This comes shortly after a similar fine was issued to Starling Bank in October 2024.   Metro had implemented an Automated Transaction Monitoring System (“ATMS”) to monitor customer transactions however, serious deficiencies in the set-up, operation and oversight of ATMS were not identified by Metro, or remediated within an adequate period of time. This resulted in the failure to monitor over 60 million transactions, with a value of over £51 billion.   At First Derivative our KYC and AML Specialists can assist with identifying any potential gaps in your financial crime operating model, ensuring your firm is maintaining an adequate risk-based anti-money laundering control framework. You can read more about our Financial Crime Services here: https://lnkd.in/ezjQNPEw https://lnkd.in/e7xJ9gCR https://lnkd.in/exy6ruGR

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🔵 The Wolfsberg Group recently published their 'Principles for Auditing a Financial Crime Risk Management Programme for Effectiveness'. But how much do we know about them, and are they being correctly applied during your financial crime audit? We explored these principles in detail during last week's webinar. At the start we asked our audience, "How familiar are you with the Wolfsberg factors and principles?". 88% responded that they were 'somewhat familiar' or 'not familiar'. After an hour-long deep dive, we asked the crowd, "In light of the Wolfsberg Group’s recent update, do you consider assessing effectiveness an important part of your audit?". 77% responded 'Yes, very important'. The consensus is clear: auditing for effectiveness is key. However, bridging the gap between intention and execution remains a challenge. Hopefully you were able to join last week's session and feel more confident about applying the Wolfsberg principles during any upcoming audit, model validation or BAU assurance activities. If not, watch it on-demand via the link in the comments! #fincrime #compliance #audit

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Free to register: Webinar. June 26, 2024 at 2pm. Join FIS and our guest speakers Ray Blake and Graham Barrow from The Dark Money Files Ltd as they discuss the growing problem of anti-money laundering (#AML) financial crime. This webinar explores why traditional anti-money laundering practices no longer work in a world transformed by digitalization, AI technologies, growing financial complexity and geopolitical tensions, and what financial institutions need to do differently. Stay proactive in the fight against financial crime with FIS. Register here. http://spr.ly/60465vbXK #CapitalMarkets #AssetManagement #InvestorServices #AML #FundAdmin #Trading #Compliance #AItech #digitalization #financialcrime #DarkMoneyFiles

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We recently published ‘Tackling Economic Crime’, a new report providing expert analysis of existing measures to combat financial crime and practical recommendations on how to address the current gaps. Download the report: https://lnkd.in/eptfdbmQ Please share this post with your network to increase awareness of this important report. #STEPProfile #EconomicCrime

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We recently launched ‘Tackling Economic Crime’, a new report providing expert analysis of existing measures to combat financial crime and practical recommendations on how to address the current gaps. Download the report: https://lnkd.in/eptfdbmQ Please share this post with your network to increase awareness of this important report. #Policy #EconomicCrime

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🚨 New Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity! 🚨 Today, the The Wolfsberg Group has published its latest guidance on Monitoring for Suspicious Activity (MSA). Here's what FinCrime teams need to know: 🔍 Key Highlights: ✔️Risk-Based Approach (RBA): Shift from prescriptive rules to risk-based monitoring for higher quality outputs. ✔️Technology Integration: Embrace new tech and innovation to enhance MSA effectiveness. ✔️National Priorities: Align with national priorities for financial crime prevention. 📊 FinCrime Specialist should: ✔️Focus on Effectiveness: Measure outputs that provide high-value information to authorities. ✔️Leverage Analytics: Enhance analytical capabilities for better risk assessment. ✔️Feedback Loop: Incorporate feedback from government authorities to refine SARs. 💡 Takeaway: Prioritise effectiveness and quality in your MSA programs to combat financial crime more efficiently. Stay proactive and innovative! #FinancialCrime #AML #Compliance #MSA #WolfsbergGroup #Innovation #RiskManagement #MLRO

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In 2022, the Financial Conduct Authority (FCA) unveiled its ambitious three-year strategy aimed at tackling financial crime in the UK. Last month, the FCA released a progress update on this strategy, outlining its achievements and setting the stage for future initiatives. The report emphasizes four key areas of focus that are essential for reducing and preventing financial crime across various industries: Data and Technology: The strategic use of synthetic datasets allows firms to model consumer behaviour and identify potential threats while upholding data privacy standards. Embracing innovative technology enhances crime detection and bolsters compliance efforts.   Cross-Sector Collaboration: Building partnerships with peers and external service providers helps firms navigate data privacy challenges and fortify anti-fraud measures. Collaboration is a powerful tool in creating a united front against financial crime.   Consumer Awareness: Educating the public and raising awareness about fraud is critical for preventing scams and protecting those most vulnerable. An informed community is a stronger line of defence against fraudsters.   Measuring Effectiveness: Firms should monitor metrics and trends to gauge the impact of anti-fraud measures, providing boards with actionable insights for strategic decision-making.   Staying vigilant and continually refining anti-fraud systems is crucial for firms to outpace increasingly sophisticated criminal threats. How is your organization rising to these challenges?

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📜 🔍 What you need to know about the PRA’s thematic findings from the internal audit review of the credit risk management framework – non-systemic UK deposit takers   The PRA asked the IA functions of 33 non-systemic firms (6 banks and 27 building societies, predominantly with lending books of less than £1.5bn) to review their credit risk management framework in September 2023. This stemmed from the high level of uncertainty in the macroeconomic environment and the expected deterioration in credit portfolios.   👇 Swipe through the slides below to see the six key areas requiring improvement based on the PRA’s findings.   Read our full breakdown for more guidance on how to tackle these areas 👉 https://lnkd.in/eU9KyKKk #4most #Banking #CreditRisk #Regulation

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Organisations and their operations in the financial sector are characterised by the complex nature of their product and service offerings. Operational Resilience of these organisations is critical to ensure a reliable and continuous service availability for their customers. Regulators in the EU with Digital Operational Resilience Act (DORA) and in the UK with the FCA Policy Statement 21/3 (PS 21/3) are looking to improve the operational resilience of the firms operating under their jurisdiction. Learn about our approach to Operational Resilience and how we can help your business assess the risk, plan uplifts and execute a program to improve resilience across your application and infrastructure landscape. 👉 https://bit.ly/3U7iPDr #operationalresilience #DORA #FCA #compliance #businesscontinuity #businesscontinuityplanning #riskmanagement #FinancialServices

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What role should OSINT play in effective anti-financial crime processes? If you’ve not read our OSINT Handbook for AFC, you can find a sample of it below. We explore why OSINT is becoming more and more crucial for AFC investigations and what financial institutions can do to harness open source information effectively – as well as how to speed up investigations processes. Read it below and download the full handbook here: https://lnkd.in/eSngY29F #OSINT #AntiFinancialCrime #FinancialCrime

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Financial crime risks are constantly evolving — are your skills and knowledge keeping pace? Get the quick, impactful training you need to stay ahead of fincrime threats with our new Emerging Risk courses, exclusively for ACFCS members. Emerging Risk courses provide brief, practical training on current and emerging financial crime typologies and risk areas, including money laundering techniques, fraud trends (like pig butchering scams seen here), and much more. Get access to all of the Emerging Risk courses by becoming a member today: https://bit.ly/43V4CNk #FinCrime #Fraud #AML #CFCS

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