On January 1st 2017 New York State’s Department of Financial Services (DFS) Part 504 went live. This rule provides a clarification on how OFAC and other lists are screened and how transactions are monitored. The impacts of this rule may…
International Sanctions – What to Expect in 2017
Sanctions were very much the “go-to” foreign policy tool of choice for actors on the world stage in 2016. Although 2017 is unlikely to be as unpredictable as 2016 it could be equally as volatile for global sanctions regimes. europos…
AFTER BREXIT, WHAT NEXT FOR FINTECH, REGTECH & COMPLIANCE?
It’s been a turbulent couple of weeks following the UK’s momentous vote to leave the European Union – and nowhere has ‘Brexit’ caused more shock and uncertainty than in the FinTech & RegTech communities, of which 80% voted to remain, according…
Is HSBC Stopping Terrorist Money Laundering? Whistleblower Urges Federal Reserve to Reopen $1.9 billion Settlement
In 2012, HSBC paid a record $1.9 billion fine to settle money-laundering accusations. Yet in a letter to the Federal Reserve, which he publicised this September, ex-employee Everett Stern (among a number of other weighty allegations) accused HSBC of ongoing…
Halting the Torrent of Stolen Money Finding a Safe Haven in the UK
In a report titled “Don’t Look, Won’t Find” released on 23rd November, Transparency International UK found the country’s AML supervision to be “fragmented”, “inadequate” and riddled with a “lack of transparency”, allowing “billions” of pounds in corrupt funds to flow…
The Inclusion of Financial crime as an FCA major risk factor
On the 24th of March 2015 the FCA released their business plan for the year. A notable aspect of the plan was financial crime replacing house price growth as a top risk consideration. Additionally, the FCA placed a special focus…
4 things we can learn from PayPal’s sanction violations
On the 25th of March 2015 PayPal agreed a $7.7m (£5.1m) settlement with U.S officials due to a breach of OFAC sanction regulation. For several years, up until April 2013, PayPal had been allowing users of their service to channel…
Why does ultimate beneficial ownership matter?
The joint-stock company is a social innovation that made possible global capitalism today. The array of corporate vehicles that it has spawned – limited liability corporations, trusts, limited companies and other legal structures – make possible the investment of capital and the…
AMLD4 and Domestic PEPS
AMLD4, the 4th amendment to the Anti-Money Laundering Act will update the European Union’s existing Anti-Money Laundering and Counter-Terrorist Financing laws by implementing recommendations made by the Financial Action Task Force, the international global standard setting body of AML and…
Effective Methods of Counter-Terrorist Financing
In a 9,000 word PhD chapter length article in the New Yorker, Mattathias Schwartz raises some interesting points.
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