Transaction laundering on mobile – new channel, new fraud

Mobile transactions are projected to reach $7,45 trillion by 2020. With the rapid growth in mobile payments comes the migration of transaction laundering to mobile as well. Transaction laundering on mobile Transaction Laundering is an action whereby a merchant processes a transaction on behalf of another merchant.  This technique is used to bypass underwriting requirements…

Would Socrates Make a Good Compliance Officer?

The following excerpt is from a PBS documentary entitled “The Greeks: Crucible of Civilization”:  By Robert Jagielski “After his service in the war, Socrates devoted himself to his favourite pastime: the pursuit of truth. His reputation as a philosopher, literally meaning ‘a lover of wisdom’, soon spread all over Athens and beyond. When told that…

Cashing out against corruption is easier said than done

When I travelled to the United Kingdom recently and got some walking-around money, I noticed that the £5 ($U.S.6.36) was sporting a sharp new design, printed on a thin sheet of polymer and featuring all kinds of next-generation anti-counterfeiting holograms, colour gradations, transparent windows, and more. I swiftly learned that the new fiver was part…

Use of data in a best practices compliance program

What does data mean? Does is lie, is it misinterpreted or simply misunderstood? The Man from FCPA has long considered data, even big data an important part of any best practices compliance program going forward. But what insights should a compliance practitioner draw from data and is it the right one going forward? Moreover, is…

The Next Generation of Compliance & Ethics Program Effectiveness: From Bolt On To Build In

Compliance activities are largely separate from business operations, functioning like “bolt-ons”-an increasingly unsustainable approach. Stakeholders now expect “built-in” compliance activities as part of the business workflow to reduce business drag and increase program impact. The Traditional Approach Is Less Effective Most compliance executives have traditionally focused on effectiveness by building their program foundations (e.g., policies,…

U.K. Law Firms Struggling with AML Due Diligence

Regulatory criticism and a series of recent judgments against U.K. law firms caught acting as financial intermediaries for criminals has fueled perceptions of widespread compliance vulnerabilities throughout the legal sector. In a 51-page report, the United Kingdom’s National Crime Agency (NCA) said last month that the legal profession facilitates complex money-laundering activity by establishing corporate…

Creating a Culture of Compliance—Can it truly be done?

Over the past few years we have been reading more and more about “creating a culture of compliance” and “doing the right thing.” At the same time, anti-money laundering (AML) regulation is becoming increasingly tougher by the hour and the day-to-day of any professional working in compliance is becoming an even bigger challenge. So, how…

Mending the Trust Divide

By Christine Lagarde, IMF Managing Director International Bar Association Conference, Washington, DC September 18, 2016 Good evening. President Rivkin, Dr. Ellis – thank you for your kind introduction. Ladies and gentlemen, distinguished guests: I am delighted to be here tonight, in the company of so many from my own profession. I still felt safe at…

An Introduction to the GDPR

Introduction For several years the European Commission has been planning a new Data Protection Regulation for European member states. Designed to provide a common legal framework for data protection law and to protect the data assets and privacy of individuals within the EU, the GDPR represents the biggest shake-up of data protection regulation in more…