Opinion


Pollution spoon feed

Why OCC ‘Fair Access’ proposed rule is a win-lose

2020-11-25T18:27:00+00:00By

How can true cooperation be achieved when the solution being proposed is essentially to pit high-risk, controversial banking customers against the banks with which they want to do business, wonders Jaclyn Jaeger.

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Crackdown on culture part of widespread regulatory push

2020-11-20T19:53:00+00:00By

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?

2020-11-12T18:10:00+00:00By

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

2020-11-02T17:39:00+00:00By

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

2020-10-21T16:45:00+01:00By

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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USAA $85M fine for compliance failures lacks justification

2020-10-16T15:58:00+01:00By

The OCC’s recent $85 million penalty assessed against USAA for compliance risk management failures leaves too many questions unanswered for a fine that size, writes Jaclyn Jaeger.

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Wells Fargo gives us another reason to doubt their culture comeback

2020-10-16T15:41:00+01:00By

While Wells Fargo ends up with yet another “Failed It” this week, we salute the principled Deutsche Bank whistleblower whose refusal to accept “dirty money” cost him everything.

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Back to the drawing board on transaction monitoring

2020-10-13T20:21:00+01:00By

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.

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U.S. agencies get nod for using data, smart incentives in enforcement

2020-10-08T17:17:00+01:00By Compliance Week

Both the CFTC and CFPB “Nailed It” this week while corporate heavyweight General Electric found itself in more trouble.

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Don’t forget to tell your teams they’re doing a good job

2020-10-07T17:31:00+01:00By

With no personal contact with your team members, it can be easy to forget to remind them from time to time that they’re appreciated, to give them a lift during these troubling times. It will pay off both for them and for you, writes Martin Woods.

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EY allegedly flubbed Wirecard dealings worse than we thought

2020-10-02T17:05:00+01:00By Compliance Week

In this week’s “Nailed It or Failed It,” we take down EY and JPMorgan Chase for apparently ignoring whistleblowers and give the SEC a nod for rewarding them.

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Progress on beneficial ownership key to AML fight

2020-10-02T16:02:00+01:00By

With the British Virgin Islands vowing its commitment to a beneficial ownership public register, financial crime expert Martin Woods turns his attention toward how the U.K. and U.S. are progressing in the space.

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With ‘FinCEN Files,’ don’t shoot the messenger

2020-09-30T18:20:00+01:00By

It’s important we understand with the “FinCEN Files” that the enemy is not a journalist, a regulator, or a banker. The enemy is the money launderer, and this is where we need to focus our thinking and resources, writes Martin Woods.

Data future

Ask a CCO: What will compliance look like in 5 years?

2020-09-30T16:57:00+01:00By Compliance Week

We asked nine prominent chief compliance officers to look into their crystal balls, and all of them saw data and advanced technology playing a larger role in the future of the profession.

Diversity & Inclusion

Ask a CCO: Compliance’s role in D&I efforts

2020-09-29T18:24:00+01:00By Compliance Week

We asked nine prominent chief compliance officers what they can do or are doing to create a more progressive workplace.

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Five ways the pandemic has changed compliance—perhaps permanently

2020-09-28T15:15:00+01:00By

It’s a good thing you’re all experts in partnering for change, as more than 3 in 4 of you think COVID-19 will have a permanent impact on some compliance functions.

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Ask a CCO: How do you keep the focus on compliance during a pandemic?

2020-09-28T14:38:00+01:00By Compliance Week

We asked nine prominent chief compliance officers what has been the most difficult part of ensuring ethics and compliance has remained top of mind for employees during the pandemic.

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BoA a silver lining in damning ‘FinCEN Files’ report; Wells Fargo CEO puts foot in mouth

2020-09-25T20:27:00+01:00By Compliance Week

Bank of America gets a pat on the back for going beyond an “observe and report” approach to filing a SAR, and we learned this week that Wells Fargo’s CEO needs a little unconscious bias training.

Career path

Ask a CCO: What drew you to compliance?

2020-09-25T16:55:00+01:00By Compliance Week

We asked nine prominent chief compliance officers across a multitude of industries what initially drew them to the compliance profession.

CCO

Ask a CCO: Which skill comes in most handy?

2020-09-24T20:17:00+01:00By Compliance Week

We asked nine prominent chief compliance officers across a multitude of industries which skill they think is most important in their CCO role.

David Lefort

Enjoy ‘Compliance Officer Day’—you’ve earned it

2020-09-24T17:02:00+01:00By

In a 2020 full of Blursdays that all run together, it’s perhaps appropriate that the day created in your honor this year happens to fall when you don’t have to be in the office (otherwise known as your bedroom/kitchen table).

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FinCEN leaks impart key lessons on basics of writing SARs

2020-09-23T20:34:00+01:00By

Martin Woods, who has analyzed many of the suspicious activity reports released as part of the “FinCEN Files,” offers best practices for compliance officers in writing SARs.

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‘FinCEN Files’ highlight bank leadership flaws, not compliance flaws

2020-09-23T19:14:00+01:00By

Compliance has been taking some heat in the wake of the “FinCEN Files” reports, but it’s banks’ senior leadership that failed, not the folks filing all those SARs.

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FinCEN leaks damage trust between banks and regulators, but serve higher purpose

2020-09-22T15:17:00+01:00By

The “FinCEN Files” leaks divided opinions within the community of financial crime compliance officers. Trust has been damaged, writes Martin Woods, but these leaks could facilitate real reform.

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‘FinCEN Files’ report casts compliance officers in unfair light

2020-09-21T21:19:00+01:00By

The BuzzFeed “FinCEN Files” investigation purportedly uncovered evidence of a catastrophic, international collapse of internal controls within the world banking system. But that argument is misleading, to the point of being disingenuous.

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Lesson for startups: Don’t try to fake compliance

2020-09-21T19:49:00+01:00By

Promising startups are often cut slack with compliance because investors feel they will eventually make it, but the time in between is ripe with dangers that extend well beyond the company, writes Martin Woods.

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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.

Carnival index

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.

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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.