Opinion


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Volkswagen completes monitorship; Deloitte family leave policy too good to be true?

2020-09-17T20:32:00+01:00By Compliance Week

Volkswagen gets a nod this week for successfully completing its 3-year compliance monitorship related to Dieselgate. Deloitte, on the other hand, lands on the wrong side of our list.

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Assessing the fallout from coronavirus relief loan frauds

2020-09-16T17:52:00+01:00By

In both the U.S. and U.K., millions (perhaps billions) of dollars of coronavirus relief loans intended for small businesses is believed to have been misused. Legitimate businesses have been hurt as a result, writes Martin Woods.

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Compliance Week presents: ‘A Tale of Two Storms’

2020-09-14T13:00:00+01:00By

Our first-ever case study is the story of Carnival’s quest for compliance redemption, set in the context of not only new leadership and a court-appointed monitorship, but in the midst of a global pandemic.

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Gut instinct keeps humans ahead of AI in fight against financial crime

2020-09-11T17:44:00+01:00By

As artificial intelligence evolves and takes on new tasks, whether it can develop the instinct of an experienced compliance professional will be key to its prevalence in the AML world, writes Martin Woods.

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Credit to JPMorgan Chase in this week’s banking-themed naughty/nice list

2020-09-10T21:14:00+01:00By Compliance Week

JPMorgan Chase, Danske Bank, Deutsche Bank, and Bank of America all either “Nailed It” or “Failed It” this week.

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Companies should give back to employees who let them into their homes

2020-09-08T15:46:00+01:00By

Where would companies be if employees hadn’t adjusted to working from home so well during this pandemic? The least firms can do is pay them back for their hospitality, writes Martin Woods.

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Forget the status quo: Proactive AML is the path forward

2020-09-04T16:05:00+01:00By

The AML community is guilty of tolerating the failing status quo, and very few have dared to confront, challenge, and disrupt the inefficient and ineffective practices. A proactive approach could be the solution, writes Martin Woods.

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Credit social media giants for prepping for election chaos

2020-09-03T18:12:00+01:00By Compliance Week

Silicon Valley’s social media heavyweights deserve a nod for “war-gaming” potential misinformation scenarios in advance of November’s elections, while McDonald’s again finds itself on our “Not Lovin’ It” list.

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Best practices KYC: What to do when your client is in the headlines

2020-09-02T15:50:00+01:00By

How do we, as AML professionals, assess negative media alerts? It should start with a conversation with the client relationship manager, but it shouldn’t end there, writes Martin Woods.

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What the Wirecard story tells us about red flags, healthy skepticism

2020-08-28T16:51:00+01:00By

How we came to learn about the fraud allegedly perpetrated by Wirecard offers important lessons in compliance and corporate governance, writes financial crime expert Martin Woods.

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Credit to KPMG for shining a light on fraud at Wirecard

2020-08-27T15:08:00+01:00By Compliance Week

A scathing report on the extensive fraud at German payment giant Wirecard had a compliance silver lining: KPMG’s by-the-books, transparent approach to a special audit helped bring that fraud to light.

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We’re losing the war on AML, and big consultancies aren’t helping

2020-08-25T15:57:00+01:00By

Financial crimes expert Martin Woods writes that, in his experience, the big consultancy firms have made a substantial negative contribution to global AML endeavors.

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Jury’s out on Wells Fargo compliance moves; Twitter #fail for Irish DPC

2020-08-20T18:33:00+01:00By Compliance Week

While it’s not yet clear whether Wells Fargo’s compliance moves (including the loss of its CCO) will pay off, we’re much more certain about the Irish Data Protection Commission’s stance on a potential Twitter fine.

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‘I don’t know’ is among a compliance officer’s strongest statements

2020-08-20T15:49:00+01:00By

Martin Woods explains how saying “I don’t know” helped him to learn and elicit the truth during his time as a financial crime compliance officer.

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Trump’s TikTok crusade a hollow win for privacy

2020-08-19T16:44:00+01:00By

There’s no questioning the need to protect the data of U.S. citizens from China, but it’s naïve to think pressuring TikTok to take up a U.S. owner is anything more than a hollow victory given our lack of federal oversight in the area of privacy.

HSBC

Hat tip to HSBC for stopping money laundering, saving lives

2020-08-18T14:36:00+01:00By

If you’re in search of proof that what you do matters, look no further than the AML efforts of HSBC in preventing $500 million from reaching the bank accounts of criminals, writes Martin Woods.

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Wells Fargo must do more than pay to redeem fake account scandal

2020-08-14T18:09:00+01:00By

Wells Fargo is now operating under a different regime, but what have the billions of dollars the bank has spent in attending to the compliance failures that arose out of its fake account scandal delivered? Not enough, posits Martin Woods.

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McDonald’s handling of ex-CEO scandal gets compliments, criticism

2020-08-13T14:37:00+01:00By Compliance Week

A fresh podcast from the Theranos whistleblower and a new compliance association for Black practitioners get a round of applause from us this week, while a complicated case involving McDonald’s lands the company on both the “Nailed It” and “Failed It” lists.

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Without guidance, U.S. companies in limbo after Privacy Shield scrapped

2020-08-12T19:31:00+01:00By

Despite a recent court ruling to scrap the EU-U.S. Privacy Shield, the program is apparently still alive and well in the United States. It’s time to move on, writes Aaron Nicodemus.

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NRA shot itself in foot with poor compliance commitment

2020-08-11T15:55:00+01:00By

The New York Attorney General’s lawsuit to dissolve the National Rifle Association might not play out as intended, but it nevertheless exposes a number of systemic compliance flaws at the organization that appear to still need to be addressed.

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Having difficult conversations is key to modern compliance

2020-08-11T15:44:00+01:00By

Now more than ever, difficult conversations are necessary and increasingly expected of compliance professionals. Financial crime expert Martin Woods has some ideas on how to make them less painful.

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Common sense KYC: Customers should supply the knowledge

2020-08-07T15:39:00+01:00By

No one knows a customer better than the customer. As such, financial crime expert Martin Woods believes the onus should be on the customer to provide the required data to keep KYC logs up to date.

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CCOs show resilience in early survey data; compliance-blind NRA in crosshairs

2020-08-06T20:41:00+01:00By Compliance Week

The National Rifle Association “Failed It” big time if a suit alleging a lack of compliance controls proves true. Meanwhile, we tip our caps to the stalwart CCOs who carry on despite a cut in pay and resources due to the pandemic.

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Firms must apply contact tracing rules to bank relationships

2020-08-04T15:28:00+01:00By

In order to prevent debacles like the one Deutsche Bank is embroiled in, there is a need to combine the processes of “know your employee” and “know your customer,” writes Martin Woods.

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What do FIFA chief, ‘Florida man,’ and Trump have in common? All Failed It this week

2020-07-30T18:18:00+01:00By Compliance Week

The lesson in this week’s edition of “Nailed It or Failed It?” is the more things change, the more they stay the same.

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While compliance is in vogue, let masks be a symbol of safety in all situations

2020-07-30T17:36:00+01:00By

Now is the time to market compliance practices to customers who wear masks within our premises but drop the masks—and their guards—when answering calls and emails from the privacy of their own homes, writes Martin Woods.

Paperwork overload

SARs overload slowing efforts to combat financial crime

2020-07-29T14:43:00+01:00By

For the global AML community, there is a need to recognize too much valuable time is spent filing too many low-value suspicious activity reports that will never become the subject of any law enforcement action, writes Martin Woods.

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Nailed It or Failed It? Disney sends anti-hate message to Facebook

2020-07-22T18:30:00+01:00By Compliance Week

In this week’s “Nailed It or Failed It?”, Disney gets kudos for throwing its weight behind the #StopHateForProfit protest, while PG&E earns criticism after being found responsible for yet another California wildfire.

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U.K.’s Russia report underscores need to question big money

2020-07-22T15:06:00+01:00By

The U.K.’s long-awaited report on Russian interference in the country stresses the importance for big money to be subject to enhanced levels of due diligence, writes financial crime expert Martin Woods.

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Using data to fight fraud fire with fire

2020-07-21T13:42:00+01:00By

When it comes to ferreting out and thwarting fraud, one must think like the fraudster, advises financial crime expert Martin Woods, who offers tips on using data to make your firm a hostile environment for bad actors.

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Want an image of corruption? Look to the victims

2020-07-16T20:42:00+01:00By

Harrowing images of coronavirus-related suffering exacerbated by bad actors plaguing healthcare systems offer a glimpse at the true devastation of corrupt activity, writes financial crime expert Martin Woods.

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Nailed It or Failed It? Twitter’s meltdown exposes major vulnerability

2020-07-16T09:29:00+01:00By Compliance Week

In this week’s “Nailed It or Failed It?”, we reflect on the most troubling aspect of Wednesday’s giant Twitter hack while giving Wells Fargo a rare kudos for being good corporate citizens.

Tightrope

Nothing more important than knowing your risk exposure

2020-07-14T16:47:00+01:00By

In performing due diligence on your supply chain partners, do not be intimidated into accepting no for an answer. Being blind to potential risks is bound to get you into trouble, writes financial crime expert Martin Woods.

Money

Analysis: When clean money is used for dirty purposes

2020-07-10T16:28:00+01:00By

There are times when it is a necessary to consider where clean money is going to as much as where dirty money may have come from, writes financial crime expert Martin Woods.

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Kudos to TikTok, tech brethren; Starbucks & Luckin have us soured on coffee cos.

2020-07-09T19:36:00+01:00By Compliance Week

In the inaugural edition of our weekly “Nailed It or Failed It?” feature, we give TikTok and other tech companies a pat on the back and shake our heads at the actions of Starbucks and Luckin Coffee.

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Deutsche Bank rightly paying the price for looking the other way on Epstein

2020-07-08T13:38:00+01:00By

In terms of Know Your Customer, Deutsche Bank knew what it had with Jeffrey Epstein. It just didn’t care enough to do anything about it.

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Ask Amii mailbag: What to do when back-to-work guidance falls to you

2020-07-02T12:50:00+01:00By

Executive coach Amii-Barnard Bahn offers some tips for when your compliance title morphs into “Chief Public Health Officer,” plus ways to highlight the compliance function at your company and more.

David Lefort

Market forces, not regs, leading the charge for data privacy

2020-06-30T19:13:00+01:00By

Data privacy is about to become a more tangible concept to Americans not due to regulation like the CCPA, but because the most influential brand in the nation is making it a pillar of how it does business.

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In time of crisis, Wirecard has turned to its would-be CCO to lead

2020-06-30T15:58:00+01:00By

Reeling from a $2 billion accounting scandal, Wirecard has turned to its would-be chief compliance officer as its interim CEO. It’s the first smart move the company has made in a while, writes Martin Woods.

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Ireland’s GDPR report shows it’s yet to hold Big Tech accountable

2020-06-29T18:31:00+01:00By

The Irish Data Protection Commission review of its GDPR investigations has come under fire for ignoring Big Tech and lacking information pertinent to inquiries into firms like Apple, Facebook, Google, and more.

PG&E

What are expectations of compliance at a negligent company like PG&E?

2020-06-29T15:39:00+01:00By

Financial crime expert Martin Woods wonders about the compliance priorities of a company found to be as reckless as Pacific Gas and Electric.

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My Compliance Library: ‘Gloom to Boom’ a guide for turning risk into opportunity

2020-06-25T17:12:00+01:00By

CW contributor Richard Bistrong shares his thoughts on Dr. Andrea Bonime-Blanc’s book within the context of the DOJ’s most recent compliance guidance and the turbulent times in which we are currently living.

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Pandemic has taught us online training/education needs work

2020-06-24T19:48:00+01:00By

The challenge of educators and trainers is to demonstrate how online learning has the ability to be “more than” it has been before. To accomplish this goal, “let’s Zoom” cannot be the only call to action.

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Lessons from Wirecard: Ignore unchallenged allegations at your peril

2020-06-24T14:34:00+01:00By

When a company does not rebut serious allegations of wrongdoing with litigation, the only response is to demand answers from the firm or take your business elsewhere, writes financial crime expert Martin Woods.

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Ask Amii mailbag: Five strategies for maximizing virtual communication

2020-06-23T15:40:00+01:00By

Executive coach Amii Barnard-Bahn provides guidance on how compliance practitioners can best have the tough conversations they need to have in a virtual environment.

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Like it or not, Clayton caught up in Trump machine

2020-06-22T20:34:00+01:00By

SEC head Jay Clayton has largely stayed out of the spotlight … until now, as he finds himself embroiled in a controversy that wasn’t of his own making. Such is life as a cog in the Trump machine.

David Lefort

Don’t let Trump’s actions lower the bar for checks and balances

2020-06-22T17:37:00+01:00By

The fact that President Trump is so unabashedly bold about holding his finger on the scales of justice should remind CCOs that ethics and rules can’t be bent for political (or business) gain.

Money laundering

Analysis: Learning to learn from our mistakes with AML

2020-06-19T14:40:00+01:00By

Scientists and doctors cannot succeed or make medical breakthroughs without being prepared to fail. The same approach should be taken to combating anti-money laundering, writes financial crime expert Martin Woods.

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Tumultuous U.S. leadership hurts image of compliance

2020-06-18T18:45:00+01:00By

If “tone at the top” is a benchmark for determining ethical leadership, where does the United States stand?

David Lefort

Why a principles-based regulatory approach works for CFTC

2020-06-18T18:01:00+01:00By

CFTC Chairman Heath Tarbert seeks to let the evolving commodities market breathe with a “principles-based” regulatory approach.