Martin Woods
Martin Woods is a former detective turned compliance officer who has experience with major compliance cases and settlements from a number of perspectives. He now applies his experience to the analysis and subsequent commentary of current compliance investigations and settlements. Previously, he advised bankers, regulators, the United Nations, central bankers, and law enforcement groups from around the world.
ArticleDeutsche Bank’s continued AML struggles worth questioning
How is it Deutsche Bank can spend more than $1 billion on compliance enhancements but still be ordered to do more to improve its AML controls? Is the bank to blame or are regulators missing the big picture?
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ABN AMRO fine response suggests moral compass of banking is shifting
ABN AMRO CEO Robert Swaak acknowledging his bank’s “moral duty” to prevent money laundering should be welcomed by all in the global AML community as progress, writes Martin Woods.
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Archegos collapse: $20 billion in losses, but a win for compliance
The collapse of Archegos Capital Management may go down as yet another episode that champions the importance of the voice of the compliance professional, writes Martin Woods.
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In the battle over whistleblowers, money matters
Is there competition among international regulators with courting whistleblowers? If so, writes Martin Woods, the path to victory is obvious: monetary incentives.
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Tolerance key to defining company culture
Many believe culture is all about conduct, but the culture sitting behind the conduct is based upon tolerance and intolerance, writes Martin Woods.
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Banks filing more SARs amid pandemic; is this the right approach?
An increase in the submission of suspicious activity reports for cash values that fall under the mandatory $10,000 transaction reporting threshold last year is a proactive step by banks, but more can always be done, writes Martin Woods.
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James Freis did the right thing at Wirecard … but why didn’t anyone else?
At the end of the sorry Wirecard saga, James Freis may be one of the very few former senior employees who can hold his head high, writes Martin Woods.
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Goldman Sachs 1MDB fallout a case study for bonus risks
As Goldman Sachs cuts the pay of its top executives in response to more than $5 billion in penalties incurred for the 1MDB scandal, Martin Woods once again ponders whether bonuses helped facilitate the improper conduct that took place.
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Compensation or compromise? The risks of compliance bonuses
Financial crime expert Martin Woods assesses whether incentivizing compliance officers with bonuses may undermine the importance of performing the job with integrity and credibility.
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Recordkeeping among a compliance officer’s greatest allies
Martin Woods writes how a recent case in the United Kingdom should remind us of the importance of our own communications and recordkeeping—especially during a time where it has perhaps never been more important.
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We’ve been failing at AML efforts, but new U.S. rules offer hope
If we fail to improve our collective AML efforts, specialized law firms will offer an inviting incentive to those who blow the whistle on our continued failings, writes Martin Woods.
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Confidence is the ultimate tool in fighting fraudsters
Con men will try to bully weak investigators and sell them their version of “the truth,” writes Martin Woods. The ultimate deterrent is to challenge their “facts” and act with the same confidence they display.
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U.S. beneficial ownership efforts a welcome sight for global AML community
U.S. Congress’ defense spending bill requiring corporations to identify who owns and controls them is a significant milestone in the global effort to put an end to anonymous shell companies, writes Martin Woods.
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Fight against corruption must go on, even if the point is undermined
The recent decision by the Department of Justice to release from custody a dangerous Mexican general must not discourage the greater efforts of the anti-corruption community, writes Martin Woods.
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Compliance should consider a well-balanced information diet
In comparing information to food, the outcome might be considered to be the same when too much is consumed, writes Martin Woods.
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Crackdown on culture part of widespread regulatory push
A recent ruling by the U.K. Financial Conduct Authority to ban three individuals from the financial services industry for out-of-work misconduct is part of a broader push by regulators to crack down on matters related to culture, writes Martin Woods.
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More data, more problems with FinCEN international transfer proposal?
A recent international wire transfer rule change proposed by U.S. regulators could go a long way toward combatting terrorist financing, but the increased transaction reporting may overwhelm an already taxed system, writes Martin Woods.
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Manchester Arena tragedy offers stark lesson in training importance
As the public inquiry into the Manchester Arena bombing of 2017 plays out in the United Kingdom, lessons can be gleaned on the importance of providing thorough and complete training to employees in all fields.
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Avoiding the compliance pitfalls of bias, bullying, and blind spots
As compliance professionals we have an important role to play in helping businesses confront and challenge the three Bs of bias, bullying, and blind spots. If we can’t see it, we can’t police it, and that is our job, writes Martin Woods.
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Back to the drawing board on transaction monitoring
In the wake of the “FinCEN Files” leaks, Martin Woods examines whether monitoring text rather than numbers in transactions could serve as a solution to our greater anti-money laundering woes.
