Suspicious Transaction Report

Sanctions have become the go-to policy tool of our times, yet the lessons of the past are often forgotten by those at the centre of the world's stage today. CFS Director Tom Keatinge speaks with Eddie Fishman, a former US State Department sanctions official, about his new book ‘Chokepoints.' Eddie gives a behind the scenes account of how the power of the US dollar and US-dominated financial and trade systems have been harnessed to support the projection of US foreign policy, and what lessons this 25-year episode of history holds for today's policymakers.

A new report from the Financial Action Task Force examines how financial intelligence can be used to protect children from online sexual exploitation. CFS Director Tom Keatinge speaks with Abi Harrison from the United Kingdom's HM Treasury and Stefan Jerga from the Australian Federal Police about a new report from the Financial Action Task Force, examining the financial dimension of online child sexual exploitation. The report, which they co-led, highlights the alarming growth of this horrific crime and the financial indicators which can be used to detect, disrupt and investigate perpetrators and safeguard victims.

With geopolitical risk rising, this episode examines a recent Dutch National Bank report on how banks should navigate growing global tensions and fragmentation. CFS Director Tom Keatinge speaks with Thomas Vos, Strategy & Policy Advisor of De Nederlandsche  Bank and Haroon Sheikh, Senior Research Fellow at the Netherlands Scientific Council for Government Policy (WRR) on the risks posed to the banking sector by growing geopolitical risk and fragmentation, their impact on society, and how the financial community should respond.

How could frozen Russian assets be used and what are the legal and geopolitical implications? Head of CFS Europe, Kinga Redlowska, is joined by Anton Moiseienko, CFS Associate Fellow and Senior Lecturer in Law at the Australian National University, along with Tom Keatinge, Director of CFS. They explore the ongoing debate about the future of frozen Russian assets, examining their potential uses and the legal, political and economic consequences for EU sanctions policy and international law.

This episode explores the role of the Financial Intelligence Unit (FIU)-the Netherlands in combating financial crime, featuring insights from its head, Hennie Verbeek-Kusters on challenges, strategies and global cooperation. CFS Director Tom Keatinge speaks with Hennie Verbeek-Kusters, Head of FIU-the Netherlands and former Chair of the Egmont Group, to discuss work at the FIU since 2008. They explore how FIU-the Netherlands operates, some of the unique features of the Dutch approach to fighting financial crime, the evolving financial crime landscape and the impact of international collaboration.

Sanctions on Belarus cover multiple issues: fraudulent elections, human rights abuses, and complicity in Russia's military aggression against Ukraine. But what is their real impact? Head of CFS Europe Kinga Redlowska is joined by Lev Lvovskiy, Senior Researcher at the Belarusian Economic Research and Outreach Center (BEROC) , and Tom Keatinge, Director of CFS, to examine the goals and effectiveness of sanctions on Belarus. The discussion covers economic impact, the Belarus–Russia alignment on sanctions evasion, and key challenges in sanctions enforcement.

Tom Keatinge and Jessica Davis explore the impact of Trump's tariff threats on Canada, alongside the country's ongoing challenges with illicit finance and money laundering. CFS Director Tom Keatinge is joined by Jessica Davis, CFS Associate Fellow and President and Principal Consultant with Insight Threat Intelligence, to discuss the rationale and impact of the threat of tariffs from the new US administration, and the policy window this might open for wider illicit finance reforms in Canada.

This episode explores the potential of whistleblower reward programmes to transform economic crime investigations. CFS Director Tom Keatinge is joined by Eliza Lockhart, Research Fellow at CFS, and Nick Ephgrave, Director of the Serious Fraud Office, to discuss Eliza's SOC ACE research paper, ‘The Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime'. Together, they examine how financial incentives could empower whistleblowers, tackle economic crime and drive cultural and systemic change in the UK. Read the full paper

Talk of state threats, hostile states and hybrid warfare has notably increased. But how do these threats differ from those faced in the past? CFS Director Tom Keatinge is joined by Matthew Redhead, Senior Associate Fellow at CFS, to discuss his new Serious Organised Crime and Anti-Corruption Evidence (SOC ACE) research programme paper, ‘Old Wine, New Bottles: The Challenge of State Threats', and to explore this increasingly prevalent phenomenon. Read the report here: https://rusi.org/explore-our-research/publications/external-publications/old-wine-new-bottles-challenge-state-threats

We explore the growing threat of sabotage attacks across Europe and the technological tools used for financing and recruitment. Host Tom Keatinge is joined by Dr Daniela Richterova, Senior Lecturer and Associate Professor at the Department of War Studies at King's College London, and Holger Roonemaa and Inga Springe, investigative journalists from the Baltic states, to discuss Russia's growing campaign of sabotage. For further reading, see Holger and Inga's reporting here and Daniela's co-authored article for the RUSI Journal on the sabotage gig economy here.

This episode explores the astonishing case of one of the world's biggest money-laundering schemes via the well-known Swedish Bank, Swedbank. Host Tom Keatinge, CFS Director, and investigative reporter Axel Gordh Humlesjö examine the Swedbank story, what led to the investigation and how, even if banks have robust compliance systems that safeguard them against criminal misuse, they remain vulnerable to those with malign intent.

How might a second Trump term reshape the US's use of sanctions? Host Kinga Redlowska, CFS Director Tom Keatinge and sanctions expert Jeff Lord examine the potential impact of a second Trump term on Russia, and how Europe should respond. With the rise of China and changing global dynamics, the conversation considers whether Trump's trademark ‘maximum pressure' tactics will resurface – or if he'll veer towards a novel and more unpredictable strategy.

Tom Keatinge and Wagner expert Jack Margolin discuss how the group became a global mercenary powerhouse and how to counter the rise of such groups. With insights from Jack Margolin, author of ‘The Wagner Group: Inside Russia's Mercenary Army', this episode explores how the Wagner Group evolved into a global mercenary enterprise, profiting from conflict worldwide. With host Tom Keatinge, they unpack Wagner's unique financial model, the strategic use of corruption, and how sanctions aim to contain these shadow networks. As new players emerge to fill the vacuum left by Wagner, they highlight the urgent need for the global community to address systemic vulnerabilities enabling such networks and to disrupt the rise and operation of similar paramilitary organisations.

Host Kinga Redlowska, Head of CFS Europe, and Tom Keatinge, CFS Director, are joined by Stephanie Baker, Bloomberg investigative journalist and author of Punishing Putin. They delve into the impact of sanctions on Russia following its illegal invasion of Ukraine, exploring Russia's evasion tactics, the role of oligarchs, and the evolving use of sanctions as a tool in global diplomacy.

Host Tom Keatinge sits down with CFS Associate Fellow Stephen Reimer and international lawyer Ishita Chakrabati to discuss how authoritarian regimes are abusing the Financial Action Task Force (FATF) standards. Drawing on insights from a two-year RUSI study, this episode analyses how the FATF standards, which aim to tackle money laundering and terrorist financing, are being exploited by authoritarian regimes to silence dissent. With the FATF gearing up for its upcoming plenary in Paris, the findings in our recent report emphasise the urgent need for the FATF to address these abuses and for the international community to take action to ensure the standards are used as originally intended.

In this episode, host Tom Keatinge speaks with Dr Marcus Pleyer, former FATF president, about his role in shaping global financial crime policies and EU anti-money laundering efforts. They explore Marcus's professional journey, from a small corner of Germany's Ministry of Finance to leading the country's successful bid to host the EU's Anti-Money Laundering Authority. The conversation delves into the initiatives Marcus championed at the FATF, including the push for using technology in the fight against financial crime and the importance of a risk-based approach in FATF evaluations.

In this episode, host Tom Keatinge, CFS Director, is joined by Andrea Kendall-Taylor, Director of the Transatlantic Security Program at CNAS, to discuss her co-authored article ‘Axis of Upheaval'. They discuss the convergence of Russia, China, Iran and North Korea and the challenges posed across economic, military, political and technological dimensions. The conversation also delves into whether these deepening ties represent a coordinated grouping or a series of ‘marriages of convenience' in response to Russia's war in Ukraine, as well as what the West should do.

In the first episode of the season, host Kinga Redlowska, Head of CFS Europe, is joined by Bethany Allen, author of Beijing Rules: China's Quest for Global Influence, a Financial Times best business book for 2023. They discuss how China has developed its economic statecraft in recent years, the innovative methods used to achieve its geopolitical ends, and what the West can do to respond to increasingly muscular Chinese economic activities.

In this teaser, host Kinga Redlowska, Head of CFS Europe, is joined by CFS Director Tom Keatinge to launch the theme for the new season, ‘The Future Of'. Listen now to get a sneak peek at the range of topics and new ideas that will feature in Season Seven of the STR podcast.

In the last episode of this season, host Tom Keatinge, CFS Director, is joined by T Raja Kumar, former President of the Financial Action Task Force (FATF). They discuss some of the key achievements during his presidency, such as his focus on asset recovery, increased FATF engagement with regional bodies around the world, the unprecedented suspension of Russia from the FATF, and what to expect as the next round of country evaluations begins.

In this episode, host Tom Keatinge, CFS Director, is joined by Darya Dolzikova, RUSI Research Fellow, to discuss her recent paper, 'Power Plays: Developments in Russian Enriched Uranium Trade'. They discuss the financial and diplomatic benefits Russia derives from its nuclear resources and industry expertise, the extent of Western dependencies on Russian enriched uranium despite some efforts to diversify from Russian supply, and the complexity in isolating Russia financially and economically.

Host Tom Keatinge, CFS Director, is joined by Geoff White, Investigative Journalist and author of Rinsed. They discuss cybercrime, money laundering, crypto hacking by North Korea, how criminals collaborate across multiple jurisdictions to evade the law, the recruitment of money-laundering mules, and the evolution of dark web marketplaces like Silk Road and Hydra.

In this episode, host Tom Keatinge, CFS Director, is joined by Justyna Gudzowska, CFS Associate Fellow, and Tom Stocks, Senior Investigative Journalist at the Organised Crime and Corruption Reporting Project. They discuss their recently published paper ‘Disabling the Enablers of Sanctions Circumvention,' the threat of frivolous lawsuits aimed at silencing independent, critical journalism, and why anonymous shell companies and trusts are the preferred tools of professional enablers to help their sanctioned clients.

In this episode, CFS Director Tom Keatinge is joined by Peter Geoghegan, Investigative Reporter at the Organized Crime and Corruption Reporting Project – a global network of journalists – and author of Democracy for Sale. They discuss the role of ‘dark money' in political funding, loopholes you can see from space, the lack of regulatory accountability on social media, the way think tanks can influence political processes, and how shell companies can be used as a vehicle to make large political donations.

Host Tom Keatinge, CFS Director, discusses the impact of sanctions against Russia with Vladimir Milov, Vice President, Free Russia Foundation.  In this episode, Tom Keatinge and Vladimir Milov discuss the impact that sanctions against Russia are having on the nation's economy and its people, the Kremlin's dwindling finances, and why Ukraine's allies must maintain pressure and focus to make sanctions work.

In this episode, host Tom Keatinge, CFS Director, is joined by Kathryn Westmore, CFS Senior Research Fellow, and Sahil Shah, Managing Director, Say No to Disinfo. Together, they explore how the spread of misinformation on social media is an emerging threat to financial stability, the role of misinformation in lasts year's Silicon Valley Bank collapse, and what banks, regulators and governments can do.

In this episode, Kinga Redlowska, Head of CFS Europe, is joined by Zoe Reiter, Director for Kleptocracy at the National Endowment for Democracy (NED), and Tom Keatinge, CFS Director and author of a new RUSI paper entitled 'Combating Kleptocracy: Lessons from the Response to Russia's War in Ukraine'. They discuss the fight against kleptocracy, how Russia's full-scale invasion of Ukraine has energised governments in their efforts to combat modern kleptocracy, and lessons from the response to Russia's war in Ukraine.

In this special edition episode of the Suspicious Transaction Report, CFS Director Tom Keatinge and Head of CFS Europe Kinga Redlowska discuss the motivation behind the programme's recent name change, upcoming research outputs, and what exciting activities will take place in 2024 as CFS celebrates 10 years of pioneering analysis and research.

Host Allison Owen, CFCS Associate Fellow, is joined by David Carlisle, Vice President of Policy and Regulatory Affairs at blockchain analysis and crypto data company Elliptic London, and RUSI Associate Fellow, to discuss all things cryptocurrency. With David's new book The Crypto Launderers: Crime and Cryptocurrencies from the Dark Web to DeFi and Beyond just out, they delve into the complex intersection of technology, regulation and crime, and the challenges law enforcement agencies face in investigating crypto.

In this episode, host Gonzalo Saiz, CFCS Research Fellow, is joined by Daniel Tannebaum, Partner at management consultancy firm Oliver Wyman, and Jan Dunin-Wasowicz, Partner and Co-Chair of Hughes Hubbard & Reed's Sanctions, Export Controls & Anti-Money Laundering practice group. They discuss the differences in the US and EU approaches to sanctions against Russia, how tackling the practice of sanctions circumvention through third countries impacts the private sector, and the role of enforcement action in countering sanctions violations.

Host Tom Keatinge, CFCS Director, is joined by Xolisile Khanyile, former head of South Africa's Financial Intelligence Centre and RUSI Senior Associate Fellow. They discuss her decades-long career as a prosecutor in the financial crime world, illegal wildlife trafficking, public-private partnerships, South Africa's FATF ‘grey-listing', and how everyday crime impacts South Africa's response to money laundering.

Host Tom Keatinge, CFCS Director, is joined by Liz Rosenberg, former Assistant Secretary for Terrorist Financing and Financial Crimes at the US Department of the Treasury. They discuss her ambitions for combatting illicit finance as she re-entered the US Treasury in 2021, her role in the review of the US sanctions strategy, the measures developed to respond to Russia's unprovoked war in Ukraine, including the oil price cap, and the priorities ahead for the US two years on from Russia's full-scale invasion of Ukraine.

Martin Sandbu, European economics commentator at the Financial Times, discusses the challenges and opportunities involved in using Russia's currently frozen Central Bank assets to support Ukraine's economy and reconstruction. The hashtag ‘Russia Must Pay' is frequently trending on social media, boosted by politicians, civil society organisations and individuals outraged by Russia's continued aggression. But while this sentiment is easy for politicians and financiers to articulate, it has yet to be matched in deeds. Martin Sandbu joins host Tom Keatinge to explore how the $300 billion of immobilised Russian Central Bank assets could be unlocked and deployed to support the Ukrainian economy and fund the huge costs associated with the reconstruction of a country devastated by Russia's illegal war.

China's regular muscle-flexing and other threatening moves towards Taiwan poses a great challenge. How should the West think about this behaviour, given the integration of China into the international economy and the extent to which the West relies on trade with Beijing? Could sanctions be used as a policy instrument here? In this episode, host Kinga Redlowska, Head of CFCS Europe, is joined by Emily Kilcrease, Senior Fellow and Director of the Energy, Economics and Security Programme at the Center for a New American Security (CNAS). They discuss the findings of a recent CNAS report entitled ‘No Winners in This Game: Assessing the US Playbook for Sanctioning China'. If you are curious about possible sanctions scenarios in the case of an escalation of tensions between the US and China, then don't miss this week's episode.

The financial crime and sanctions world has mushroomed into a global industry. Thousands of compliance officers, analysts, policymakers and law enforcement officials are involved in some element of this behemoth. Among these many thousands, a few figures have emerged as opinion formers – those who found themselves at the forefront of developments. In this episode, host Tom Keatinge, Director of the Centre for Financial Crime and Security Studies at RUSI, is joined by Danny Glaser who has spent over 20 years at the heart of US efforts to advance the fight against financial crime. They talk about sanctions, terrorist financing, and the ‘most powerful organisation few have ever heard of': the Financial Action Task Force (FATF).

Sanctions circumvention has been at the core of policy discussions on restrictive measures. But what does ‘circumvention' mean, and what is the on-the-ground reality in the countries that are so often associated with this activity? Host Kinga Redlowska, Head of CFCS Europe, is joined by Carl Schreck, investigative journalist at Radio Free Europe, and Olivia Allison, CFCS Associate Fellow, to discuss the challenge of tackling sanctions circumvention and evasion.

While the tempo of Russia sanctions issuance has dropped off, policymakers and diplomats are working to boost their effectiveness. But what does ‘sanctions effectiveness' mean and how can we measure it? And are sanctions serving their purpose to undermine the Russian war machine? Host Kinga Redlowska, Head of CFCS Europe, is joined by Elina Ribakova, Non-resident Senior Fellow, Peterson Institute for International Economics, and Timothy Ash, Senior EM Sovereign Strategist, BlueBay Asset Management, to discuss the challenge of assessing the effectiveness and impact of sanctions on Russia.

Those in the private sector can often feel stuck between policymakers who fear cryptocurrencies are undermining their carefully built regulatory fortifications, and the online world of dark markets beyond those regulatory walls. Host Tom Keatinge is joined by co-author Allison Owen, CFCS Associate Fellow, and Rodrigo Peiteado, Senior Manager of Digital Asset investigations at BVNK, to discuss a new virtual asset risk assessment guide for the private sector published by the CFCS: Institutional Virtual Asset Service Providers and Virtual Assets Risk Assessment Guide | Royal United Services Institute (rusi.org)

Effective implementation of sanctions requires cooperation with partners around the globe. Host Tom Keatinge, Director of CFCS at RUSI, sat down with EU Sanctions Envoy David O'Sullivan in Brussels to explore the EU's approach to negotiations with third countries to clamp down on the circumvention of sanctions, emphasise the importance of data in sanctions diplomacy and stress the role of the private sector in making sanctions effective.

Before 7 October 2023, the terrorist threat posed by Hamas was largely clouded by preoccupation with geopolitical tensions and the ongoing war in Ukraine. But not anymore. Hamas's coordinated attacks on Israel and the resultant conflict has made the terror group's threat and its financing unavoidable. Host Stephen Reimer unpacks the key issues and debunks some common myths at the heart of the Hamas financing story with Jessica Davis of Insight Threat Intelligence and Matthew Levitt of The Washington Institute for Near East Policy.

Recently, the political class in Westminster has been consumed with with the conduct of bank accounts or, more specifically, when these are being closed, unilaterally, by banks. It's a long running problem. Might the spotlight brought to the issue by Nigel Farage finally create some overdue action by the UK government? In this episode, host Tom Keatinge is joined by Izabella Kaminska from Politico and the Blind Spot, and Siddharth Venkataramakrishnan, the Financial Times' banking and fintech correspondent, to explore what has been going on – and why the Farage farrago is perhaps old wine in new bottles.

As multilateral organisations battle strong geopolitical headwinds, the Financial Action Task Force (FATF) – the global financial crime watchdog – is not immune to such pressures. Indeed, it faces a range of challenges that are increasingly raising questions about its continued legitimacy. In this episode, host Tom Keatinge explores what these challenges are and how the FATF might stay ahead of them with two former FATF insiders, David Lewis and Michelle Harwood.

Tom Keatinge and Alanna Putze, two of your CFCS podcast hosts, introduce a new concept for the Suspicious Transaction Report podcast, offering listeners fresh content on the intersection between finance and security. Here is a glimpse of what's in store, including some of the guests, topics and ideas that will feature throughout the season.

Is there a resurgence of state threats or have democracies just opened up their eyes to this complex challenge? In a season that explores today's varied threat landscape, this final episode delves deeper into the dynamics between economics and security. Host Tom Keatinge is joined by RUSI Trustee Suzanne Raine and Associate Fellow Jason Shepherd to discuss the blurring of geopolitics and finance through the lens of history and look at what must happen to strengthen democratic resilience for the future.

How do adversarial states exploit cyber to pursue their own strategic objectives? From intelligence gathering and information operations to physical disruption and financial gain, cyber operations are increasingly shaping the global threat landscape. And it's not just large state actors such as Russia and China that are behind them, but also dozens of emerging states, along with contractors and private entities. Dr Jamie Collier of Mandiant joins host Alanna Putze to explore the implications of this multifaceted threat and whether democracies are on track to respond.

Disinformation is not new, but it has certainly evolved. Today, it is strongly linked to international security, as malign actors seize on it to pursue their own strategic interests. Are democracies equipped to navigate this new landscape of political warfare? Host Alanna Putze is joined by Monika Richter of the American Foreign Policy Council and Graham Brookie of the Atlantic Council's Digital Forensic Research Lab to explore the multifaceted scope of today's disinformation challenge, and why tackling it is vital for democratic security.

Hybrid warfare is on the rise. From cyber and disruptive technologies to energy security and economic interconnectedness, malign actors have an array of domains to exploit. How has NATO adapted, and can it be nimble enough to stay ahead in a rapidly evolving threat landscape? Host Tom Keatinge is joined by James Appathurai, NATO's Deputy Assistant Secretary General for Emerging Security Challenges, to explore how the military alliance is building resilience and the private sector's vital role in this effort.

How are organised crime and illicit finance exploited as vectors of state-based threats? This episode focuses on Russia and the unique capabilities it gains via illicit proceeds, including the power to subsidise occupation. Host Stephen Reimer is joined by Tena Prelec of the University of Oxford and Rowan Newman of the UK government's Serious and Organised Crime Network as they explore the blurred lines between government, business and criminal actors and the impact on international security.

Interference and influence – whether in politics, national institutions or boardrooms – has long been an objective of adversaries of democracy, who frequently deploy money in pursuit of their goals. This episode spotlights Latvia, a country that is no stranger to corrupt external influences. CFCS's Tom Keatinge is joined by journalists Sanita Jemberga and Edward Lucas to explore what went wrong in Latvia, why the rest of Europe is not immune to this threat, and what must be done to safeguard democracy.

What role do non-state proxy groups play in the current global security framework? This episode focuses on the Wagner Group, which has the potential to aid Russian state interests on multiple fronts, and not just on the battlefield. Host Stephen Reimer dives into the murky world of the Wagner Group, state threats and finance with guests Justyna Gudzowska, director of illicit finance policy at investigative NGO The Sentry, and Jason Blazakis, director of the Centre on Terrorism, Extremism and Counterterrorism at the Middlebury Institute in Monterey, California.

Are the UK and its allies sufficiently equipped to tackle today's threats from hostile state actors? And how might placing those threats under a financial lens help to shape responses? Host Tom Keatinge is joined by RUSI Associate Fellow and Senior Specialist at the House of Commons Ashlee Godwin, and Jonathan Evans, former Director General of MI5. They set the scene for this season's theme of ‘finance weaponised', exploring the evolving state threat landscape and how it might impact the future of democracy.