Captivated Audience: A Financial Crime Podcast

Marie Lundberg and Sam Sheen are joined by Ina Rothe who explains the twists and turns of using Germany's Company Register (referred to as the Transparency Register) as part of the KYC process.  Did you know that Germany has more than one register or that the information you want might be spread across several different registers? Or how about needing to pay to get access to some KYC information and the various exemptions that allow some legal entities to provide nothing at all? If you work with customers who have businesses using German legal entities, this episode is a great practical tutorial on how to wrangle this no-so-transparent corporate register.AND as they say, serendipity is a funny thing - following the recording of this episode, a new law, the Transparency Register and Financial Information Act, came into force in Germany on 1 August 2021.  The changes it introduces are intended to transform the German Transparency Register to  provide direct information on beneficial owners for all legal entities with very few exceptions - without having to refer to other registers as has been the case up until now.  Many a legal entity so far exempt from notifying the transparency register of their UBOs will now have to make the effort to report UBO information, even if it may already be listed on other registers. There is a transitional period for legal entities to comply and report and users of the transparency register may - in theory - expect completion of UBO input by the end of 2022. 

Jane Jee, Chair Kompli-Global Limited and Chair Project Financial Crime, Emerging Payments Association (UK) talks to Marie Lundberg and Sam Sheen about her involvement in the pre-consultation in her role with the Emerging Payments Association to urge the UK Government to engage more with RegTechs as part of their planned review of the Money Laundering Regulations and the plans in the UK for its well known corporate registry - Companies House. Jane shares the story of Kompli's evolution of its financial crime RegTech and how it has leveraged the data from Companies House to better detect odd things in the registry's data. Jane, Sam and Marie look at the nine-fold increase in requests for information by enforcement from Companies House for investigation purposes; the upcoming changes that will be introduced by the registry to change the way in which they operate, their powers to verify data, requiring companies to do more in terms of how they supply the data, Companies House business plans involving massive transformation from technology usage, process and even culture. Jane talks about the extent to which Companies House has reached out to RegTechs to see what the potential tools at their disposal are along with the overall need by regulators to also harness the use of RegTech to undertake their supervisory tasks and make them more efficient.Jane concludes her chat by sharing some sage advice on how best to check the data on a register and the places KYC reviewers may not think to look for that might suggest a financial crime red flag has unfurled. 

Marie Lundberg and Sam Sheen are joined again by Al Catto, Managing Director of Beyond, to discuss all things change related when it comes to AML/CFT compliance programs. We start Part 2 by discussing the way in which FinTech's approach change and its impact on key AML projects; the importance of test planning to make sure the change you want has the intended impact,  and the politics involved in major change initiatives. We also explore the risk of being too inflexible when it comes to your change plan, how it's unrealistic to expect it to all go perfectly and the value in being flexible - you don't always get it right even as the Change Coordinator. We also consider how best to deal with those "naysayers" who have little faith that the RegTech you want to use will improve your customer onboarding. And finally - what makes for a a successful "change conductor" - should you wallow in the compliance drama or can you rise above the mayhem like a former colleague known as "the Smoke" (you'll have to listen to find out!).

Ch-ch ch-ch changes! Al Catto joins Sam Sheen and Marie Lundberg to talk about his company, Beyond and their speciality - change transformation involving AML/CFT programmes.  Turning around failed RegTech or even onboarding processes is no easy task. Al shares his insights on the good, the bad and the ugly when it comes to successfully implementing a transformation project.  Want faster KYC? Streamlined CDD onboarding? Will KYC RegTech solve the cost of compliance every time?  And where does customer data fit into all of this?  Learn about the tips - and traps - that firms often fall into when trying to solve that ever present problem - the balance between operations and customer satisfaction and the cost of financial crime compliance. Part 1 of 2 podcasts.

David Christie, Chairman of Bleckwen, joins Marie and Sam to chat about the amazing world of behaviour detection and how Bleckwen has harnessed machine learning to better detect fraudulent and suspicious behaviour. With a name linked to a "truth serum", Bleckwen has been involved in some "deep truth" investigations dealing with better detection of complex fraud such as PPP fraud, where it is a challenge for banks with larger legacy systems. Credit origination fraud, synthetic ID fraud, and oddities in transaction monitoring patterns, according to David it's all about behaviour.  Marie dives into the use of graph theory - did you know it was used to design London's tube system? - the same approach is used by Bleckwen to identify patterns across banks accounts and parties, how they interact, how often and other similarities.  David also explains how they encourage their team to go further afield to keep their thinking fresh - could Tweets prior to the Catalan unrest in 2018 have helped to detect it earlier?  Sharing their intelligence and some of their algorithms to the wider financial crime prevention community (for free) is an important part of Bleckwen's approach to being a part of the financial crime community. 

Sam Sheen and Marie Lundberg are joined by Aamir Hanif, a globe-trotting financial crime compliance expert, to talk about all things related to free ports and free trade zones.  Having been identified as having an elevated risk for financial crime, Aamir explains how Free Trade Zone companies are operated, who controls them, accessing KYC information about their UBOs, while Marie raises a good point: Maybe when it comes to free ports, what do we need to do to "know your container".  With reported risks of FTZ and the link connected to the volume of conterfeit goods traded in a country.  With the UK soon introducing its own free ports post-Brexit, this is a must listen for fellow financial crime compliance professionals.

Elizabeth Slim joins Sam Sheen and Marie Lundberg for part 2 to chat about the Anti-Money Laundering Act 2020 (AMLA) and how this significant reform will impact areas such as new protections for corporate whistleblowers that now includes MLROs, auditors or even an attorney, along with the upping of the payments made to them. They also consider whether an overseas staff member is protected under the AMLA if they blow the whistle on financial crime in their sister company in the US, an update on Virtual Asset Service Providers, antiquity dealers joining the regulated AML family and new provisions for enforcement actions and penalties.  Look out - bonus claw backs and banning from acting as a director in the future are now in the goody bag of penalties!

Elizabeth Slim joins Sam Sheen and Marie Lundberg to chat about the Anti-Money Laundering Act 2020 (AMLA) and how this significant reform will impact areas such as Beneficial Ownership rules, FinCen's planned review of the art market from an AML perspective and whether overseas businesses with subsidiaries in the US need to comply with these requirements. They also consider the not-so-simple UBO rules, when companies must register their owners and the many exemptions offered under the AMLA Act , expanded provisions for US government to obtain records from non-US banks and how they could lose their correspondent bank account if they fail to cooperate. And of course, sharing of information between entities as part of a new pilot project.  Part one of two.  

Eric Sohn joins Marie and Sam to talk about some recent decisions and fines imposed by the US sanctions regulator, OFAC, and their possible implications for firms and how they conduct sanction KYC and screening. This is a must listen to episode as Eric and Marie share their practical advice the different ways professionals can approach their list management practices, how they conduct sanctions KYC and what it means to take a risk-based approach. 

Marie Lundberg and Sam Sheen chat with Encompass Co-Founder and CEO Wayne Johnson currently in Australia, to chat about the goal of achieving a single digital risk profile of a customer, as part of a tech-enable financial crime prevention programme.  Wayne explains the concept of "Intelligence Process Automation" or IPA, and how it's intended to make the onboarding process of customers more efficient and effective, while still detecting bad actors.  And no chat about KYC would be complete without  touching on the challenge of adverse media screening, the goal of having a "single KYC digital customer profile" and a "show and tell" us story where Wayne explains how his company, while running a demo of their technology to one bank, revealed just who really owned and operated one of its customers.

Sam Sheen and Marie Lundberg welcome George Voloshin back to the podcast, where they look at the European regulations that prevent businesses from refusing business on the grounds of needing to comply with the USA sanctions regulations related to Iran.  George and the hosts look at court decisions where companies have been challenged by customers who've refused services or ended business relationships - and whether the reasons they gave were considered compliant with the EU Blocking Regulations.  This podcast considers how contract clauses used in your customer agreements may clash with your firm's sanction compliance obligations under those Regulations. Why did one firm successful defend their "No Iran business" OFAC clauses because of correspondent banking?   As always, nothing is as simple as it seems when it comes to sanctions compliance!

In the final part of the series, Marie and Sam discuss how remote onboarding has proven to be an essential lifeline for many businesses during the pandemic.  However, the European Banking Authority's Opinion reflects that AML regulators in the EU are still concerned that businesses may not be onboarding customers in a way that effectively mitigates those classic "non face to face" financial crime risks. Hear what their proposal to address this is - and of course, no opinion would be complete without revisiting the UK's departure from the EU. Have those dreaded financial crime risks identified by the EU in 2019 related to Brexit actually come true?

In Part 3 of this series, Sam and Marie discuss the concerns that EU AML regulators continue to have around crowdfunding platforms - both as customers of financial institutions and as businesses in their own right.  They also consider the EBA's assessment of fraud and related financial crime risks that have arisen in 2020 during the COVID pandemic - what should firms have been doing to mitigate those risks? What should regulators have been doing to keep supervising, despite lockdowns 1 -2 and now 3.  And despite requiring Business Continuity Programs, could regulators have done more to ensure that firms were "risk ready" and able to adapt to the new normal in which we're currently working? 

Continuing with a detailed review of the European Banking Authority's Opinion on the Financial Crime Risks facing financial services businesses in the EU, Sam and Marie discuss how FinTechs are still considered to pose an elevated financial crime risks in the EU, concerns around the use of remote onboarding and other RegTech and why the terrorist financing risks are not seen to have changed since 2019 and what's needed to address it. Sam and Marie also take a quick peak at what the newly revised Risk Factor Guidelines require when it comes to addressing terrorist financing, and its possible impact on existing financial crime compliance programs.

After a short hiatus, Sam and Marie return and kick off 2021 with a detailed review of the European Banking Authority's Opinion on the Financial Crime Risks facing financial services businesses in the EU. Looking at the updated to the EBA's findings first published in 2019, Sam and Marie explain the methodology applied in assessing various financial crime risks and the measures the EBA proposes will help to mitigate them. Part 1 of this series looks at the EBA's assessment of the Cryptocurrency sector - and which types of businesses are thought to have the greatest financial crime risks when dealing with both virtual currency providers, and the virtual asset service providers. 

Marie and Sam chat with Araliya Samme about her role at RegTech firm, Featurespace, the detection of unusual behaviour using machine learning as part of financial crime investigations to better detect and report suspicious activity,  How behavioural analytics work in practice and why the 'one size fits all' approach to compliance monitoring is quickly becoming obsolete.  They also explore the crime trends seen during the COVID crisis and how the use of money mules has been on the increase, where Araliya shares a case study on "inter-minglers"  or customers who hold multiple bank accounts as a tactic to obscure the overall flow of funds and the sources from which they came.  She also shares a great illustration on why source of wealth and funds forms a part of CDD and how Featurespace technology was able to  help one bank say in relation to one customer, "I don't think so".And forget about how to tame your dragon, how do you go about taming and training your behavioural AI? Listen and find out?

Gavin Keeley, CEO of  Search 365 in Queensland, Australia joins  Marie and Sam to chat about his company's search engine technology and his partnership with Basis Technology, Gavin's global work in the regulated insurance sector and how fraud risks have arisen for that sector during the COVID crisis and a solution formulated for one insurer when 980 000 Australians were made redundant, triggering a mass of insurance and all of their support centres  were unstaffed due to COVD restrictions. How did they come to the rescue? You'll have to listen to find out how they 'just let the AI rip' , extracting data from documents, handwritten content and other diverse data sources, in a matter of minutes. At the same time, hear how Gavin's company combined 365's search tech with Basis' semantics technology to detect those "suspect salmon" fraudsters trying to hide amongst a school of claimants.

Marie and Sam chat with Vincent and John from Facepoint about identity fraud concerns including identity impersonation versus identity theft, tactics used by fraudsters to conceal their identity, data and risks related to demographic data discrimination, and how biometric technology is being used to detect and disrupt fraudsters and other illicit actors.

Elizabeth Slim joins Marie Lundberg and Sam Sheen to chat about the recent FinCen Guidance on politically exposed persons ("PEPs")  in the USA and how it differs from similar regulations in the UK, her work in founding her local ACAMS Chapter. Elizabeth chats about the PEPs identified in the FinCen leaks, the changes to PEP lists anticipated following the US election and what financial institutions need to do now to stay ahead of the game.

Dr Annalise Vineer joins Sam Sheen and Marie Lundberg for a chat about the thorny issue of financial crime investigations - are banks hitting the mark? What causes their investigations to "fail"? Why are relationship managers so critical to an effective investigation? Annalise also explains why knowing how and what to ask bank personnel AND customers is not a skill to be taken for granted and what can be done to make those SARs more useful for law enforcement.

Just like the recent raining weather, yet more leaks have taken place in the financial crime community.  Sam Sheen interviews Marie Lundberg on how financial institutions have and should respond when data leaks occur, lessons learnt from the 2016 Panama Papers leaks and what Marie would look for as an internal auditor if she was assessing how your firm dealth with this most recent piece of adverse media.  Is there a silver lining on this otherwise rainy day piece of news?  Listen in to find out!

Marie Lundberg and Sam Sheen chat with Ben McKee about why natural language processing is the "secret sauce" behind effective adverse media screening as part of a good financial crime compliance programme,"googling" for bad news, using artificial intelligence to search from adverse media semantic meaning to better pinpoint relevant adverse media, lessons learnt from the 1MDB case, a recent complex COVID fraud case involving the use of social media promotion, real life financial crime cases detected through adverse media screening and whether it's possible to undertaken adverse media screening across multiple languages and some sage advice on how to succeed with business development in this new virtual normal environment.

Marie Lundberg and Sam Sheen chat with Francisco Mainez, on his career transition from military intelligence to financial services technology, the role of Data Analytics in a financial institution and how it supports financial crime investigations, moving towards a more effective transaction monitoring methodology by moving from a rules-based approach to one based on machine-learning, whether "one size fits all" approach to transaction monitoring rules works for firms with a global reach, mitigating the potential risks of customer risk profiling that may lead to financial exclusion for some consumers. Francisco also talks about the recent pilot his team is running in using different monitoring scenarios based on the regional financial risks experienced by two different jurisdictions along with that age old problem of data quality and the best way forward and the possible future use of micro-segmentation to align customer risk profiles with their ongoing transaction activity.  

Chris Brown, VP International Basis Technology chats with Marie Lundberg and Sam Sheen about his career move from professional footballer to financial crime technology innovation, the age old problem of screening customer names, transliteration and the Boston Bombers, links between PEPs and their family members, use of computational linguistics, the challenges of screening using phonetics alone, shedding the "black box" approach as a technology provider, and and criminals creative use of lexicons and how Basis' technology uncovers semantic similarities to detect nefarious communications. Think you can avoid detection by referring to "barbeques" instead "laundering" in phone texts or emails? Find out how Basis tackle this challenge. 

Gudmundur Kristjansson, Founder and CEO of Lucinity and its Principal Data Scientist Justin Bercich chat with Sam Sheen and Marie Lundberg about their company's offering of "Human AI", and how its behavioural analytics technology is helping analysts to better detect possible financial crime activity, beyond traditional transaction monitoring techniques. The group chat about the hosts beloved topics - data, privacy - and learn about Lucinity's use of homomorphic encryption, while sharing a story of how their technology had helped to detect suspicious activity in real life. And Lucinity's motto raises an interesting question:  You know where your avocados are sourced from, but if you;re a business, do you ask yourself that same question about your money? You''ll have to listen to find out.

Chris Taggart, CEO and Co-Founder, OpenCorporates joins Marie Lundberg and Sam Sheen for a chat about the work of OpenCorporates, the biggest open company database in the world, their recent report " EU Company Data: State of the Union 2020 How poor access to company data is undermining the European Union", the importance of data access and aggregation, investigation of nefarious actors hiding behind corporate structures, the importance of transparency and public access to deterring the misuse of companies by illicit actors and the real financial cost to financial institutions trying to access some company registry data here in Europe and OpenCorporates move from a snapshot database to an iterative continuous information tool.

Vincent White, UK Director, Facepoint chats with Marie Lundberg and Sam Sheen about the use of biometrics and facial recognition technology for KYC and in the detection of illicit actors; the future of biometrics as a component of customer due diligence, its use in improving sanction screening results and screening in general, GDPR and privacy considerations and whether make-up, tattoos or plastic surgery can be used to confound biometric matching.

Marie and Sam continue their discussion with David about how to find CDD or adverse media about an "invisible" or "disappearing" clients, the potential for continuous KYC, the use of recall with trade data to generate risk signals across large global populations to detect trade-related financial crime; whether to Google or not to Google search for KYC purposes and focusing on the real problem to solve in order to make data-driven decisions. And why Carrie Mathison from Homeland (tv character) might not make the best AML investigator.

Part II of Sam Sheen and Marie Lundberg's discussion with Eric Wagner, Head of Financial Crime, Erste Group where they review the changes that the Working Group have proposed to eIDAS and EU AML regulations to allow for greater reliance by financial institutions on eKYC, the absence - and importance - of a single standard on eKYC - and the many different groups working separately on their own set of standards and why cracking the problem of KYC in Europe is fundamental to its future as a digitally enabled economy.

Charlie Roberts, Head of UK and EU, IDNow (the Wirrall,  England, joins Sam Sheen and Marie Lundberg to chat about this company's eKYC technology and the use of live video verification across the Benelux region and beyond, detecting possible duress by IDNow's agents to mitigate the risk of illicit actors pressuring innocent individuals to open accounts on their behalf and why it's best not to include your emotional support alpaca when applying for an online account.

Mark Gilmartin, Senior Tax Advisor, Efficient Frontiers International Limited chats with Sam Sheen about the connection between AML KYC and tax KYC in relation to legal entities and shares some interesting case studies illustrating the tactics used by different actors to conceal their identity for tax purposes while also laundering the proceeds of crime. 

Eric Wagner, Head of Group Financial Crime, Erste Group talks with Sam Sheen and Marie Lundberg about his role as rapporteur of the European Commission Working Group on eKYC and the possible expansion of the eIDAS programme for use by the private sector for KYC in the future. Eric shares his insights on the key changes needed to allow financial institutions to rely on electronic ID verification across the EU and why the best route to achieving regulatory change is pure logic. 

David Buxton, CEO and Founder, Arachnys Information Services Limited chats with Marie Lundberg and Samantha Sheen in Part I of his podcast about the importance of data in detecting and preventing financial crime, single source of truth approach for data aggregation, the spectrum of data sources relevant for financial crime prevention, desktop RPAs and bots, best practices for leveraging open source data, the challenges in relation to sanction lists and other structured data and the essential role of the analyst in "devining" the reliability of unstructured data sources. 

Nick Maxwell, Head of FFIS research partnership between the RUSI Centre for Financial Crime & Security Studies and NJM Research chats with Marie Lundberg and Sam Sheen about public -private partnerships establishing and developing across the globe to exchange valuable information for the detection and prevention of financial crime, both at the national level and across jurisdiction.  Nick shares his research into the important elements for the successful collaboration between the public and private sector and how PPPs can scale up to include a broader scope of the private sector community.

Jeff Bateman, Director of Operations of EFI Limited continues his discussion with Sam Sheen about his work on the KYC Utility Clarience, challenges and lessons learnt from it, the dilemma faced with address data, facing up to effective resourcing around KYC reviews and remediation timelines, the importance of combining human and automation tools and how EFI provides its clients with support for this approach, his team's most essential asset and the most important considerations for him in easing out from under the social distancing restrictions at work. Jeff also explains why updating your KYC procedures is like course correcting for a tanker vessel.

Adam McLaughlin, EMEA Head of Financial Crime Solutions, Nice Actimize chats with Sam Sheen and Marie Lundberg about his career in financial crime prevention including his time as a police officer, his work with the UK public-private partnership initiative JMLIT and the capital markets group, the innovative tools developed by NICE Actimize to detect and report on financial crime and how in one case it detected an interesting case involving the possible misuse of products in the insurance sector. They also chat about the challenges of SARS, their conversion into meaningful investigations, some great tips for businesses deciding which automated tools best suit their needs and the idea of the single data hub offering being developed by his company.  And how to use artificial intelligence to reduce false positives. 

Jeff Bateman, Director of Operations, Efficient Frontiers International Limited chats with Sam Sheen about the alchemy of operationalising KYC requirements, the importance of maintaining nimble operations, the black hole of time for KYC reviews, the importance of aligning operations and compliance when discussing AML-related remediation projects and how to maintain positive regulator engagement and trust.

Christopher Ghenne, Global Lead - Banking Compliance Solutions - SAS joins Marie Lundberg and Sam Sheen to chat about how he supervises 600 team members across 50+ countries over the restricted period, the evolution of the SAS transaction monitoring tool and its use of big data, the use of advanced analytics and text mining and analysis of unstructured data for sanctions screening. They also discuss the challenges of sanctions screening and the dance between transaction monitoring and name screening and why text mining makes it move more smoothly across the compliance dance floor. If you have ever wondered how to set up an effective monitoring tool, this is the podcast to listen to!

Ben Marsh, Chief Executive, iMeta Technologies Limited joins Sam Sheen and Marie Lundberg for Part II of his podcast.  They discuss an iMeta project involving the mapping of customers across business lines in terms of their trading activities and what this disclosed, the future of managed services for conducting KYC by financial institutions, whether the regulation of KYC technology providers might be on the horizon, iMeta's work with the Nordics KYC Utility and the next exciting thing on the RegTech horizon.

Martin Walker, Consultant, I&DM Advisors, (Stockholm, Sweden recorded on 19 May 2020) chats with Sam Sheen and Marie Lundberg for Part II of his podcast where they share experiences about epic technology project "fails" in their careers and projects don't make it to the finish line, the Nordics KYC Utility, the complexities of data management and reliable data sources and the importance of the corporate registers for KYC purposes.  They also talk about the "golden rule" on the consistent use of the same identifiers to achieve cross jurisdictional KYC activities.  And always, we talk the importance of data - and how to address garbage in and garbage out - for an effective KYC process - across corporate registers.

Martin Walker, Consultant, I&DM Advisors talks with Marie Lundberg and Sam Sheen about working as a British ex-pat in Sweden, the importance of business architecture and the supporting role of the IT function, the importance of understanding how data flows and its use inside a financial institution, the challenges of data aggregation, the importance of understanding the difference between data at rest and data in motion and the move towards event-based processing for AML purposes and how timing is everything when it comes to data processing. And his recent role as the interim CIO for the Nordics KYC Utility. And tackling the big question: Compliance and IT teams: Can they ever work collaborate on successful AML technology projects?

Ben Marsh, Chief Executive, iMeta Technologies Limited chats with Marie Lundberg and Samantha Sheen about accelerating customer journeys, client lifecycle management, the move from process driven AML compliance to data driven financial crime prevention, the importance of being able to move data electronically for KYC purposes, the transparency of external data sources such as company registers and their accessibility along with the concept of "continuous KYC".

Alexon Bell, Executive Director & CPO, Quantexa chats with Marie Lundberg and Sam Sheen about entity resolution, data curation, transaction pattern detection, the importance of context, cases Quantexa has helped with involving trade based money laundering, correspondent banking and the importance of understanding networks of relationships in detecting and preventing financial crime. 

Dr Ellison Anne Williams, CEO and Founder, Enveil (Washington D.C. USA,on the securing of data in use, the data security triad, the "holy grail" of cryptography - homomorphic encryption, how it works, its use for securely sharing data for the detection and prevention of financial crime, the potential for cross-jurisdictional information sharing while still protecting personal information, sweeping the 2019 AML Techsprint co-hosted by the UK and USA regulators and dispelling the dreaded "black box" concern of regulators around how AML/CFT RegTech works.

Denisse Rudich, Founder, Rudich Advisory, speaks with Marie Lundberg and Sam Sheen about her career in banking, FinTech and AML/CFT compliance, working with an NGO, the role of the G7 in relation to AML regulation of cryptocurrencies, her upcoming project that's keeping it in the family - ELEMENTARYb and why Angela Merkel rocks the power suit.

Jayne Newton & Joanna Ricketts, Efficient Frontiers International talk about their collaborative working experience on developing in-house compliance RegTech, overcoming user skepticism, building a strong relationship between compliance and technology teams and lessons learnt on building a successful RegTech tool so you don't deliver a "blue bungalow" (you'll have to listen to find out!). 

Mark Gilmartin, Expert Tax Advisor, Efficient Frontiers International chats with Sam Sheen about the different financial crime tactics used to commit tax evasion, from the structuring of products like film financing schemes, tax evaders from your 90 year old granny who does not want to pay her taxes to unwitting beneficiaries of complex trust arrangements,  challenges of distinguishing between tax avoidance and tax evasion and a great list of tax evasion red flags to look out for.  And Sam and Mark consider the magic ingredient to achieving AML-Tax KYC harmonisation across Europe and further afield.

George Voloshin, Corporate Intelligence and Investigation Specialist, Aperio Intelligence joins Marie Lundberg and Sam Sheen where they look at secondary sanctions, sectoral sanctions imposed on Russia and our Part III on the Swedbank case on the observations made in the Clifford Chance investigation report about transactional activity and sanctions compliance.  Iran, Crimea, Cuba - things that make you go hmm?

Mark Gilmartin, Expert Tax Consultant, Efficient Frontiers International, takes Sam through her paces on why tax KYC matters, how to work with it in conjunction with AML/CFT KYC requirements and why the new 5th Anti-Money Laundering Directive (5AMLD) requirements are so important to the detection and prevention of financial crime. 

Sam Sheen chats with Matthew Pedley-Thomson about an elaborate fraud scheme involving the misuse of government grants, student accounts carrying cash to Iran, a Mazarati sports car and why you never can fool a money sniffer dog at the airport.

George Voloshin, Corporate Intelligence and Investigation Specialist, Aperio Intelligence, joins Marie and Sam to discuss Sectoral Sanctions and tactics used to evade their restrictions, red flags, screening tips and the importance of beneficial ownership of legal entities and the Swedbank case information about sanctions compliance.