Grahame White has recently retired as a detective from New Scotland Yard and has joined ACAMS as head of European Operations. His previous experience includes 12 years at the National Terrorist Financial Investigation Unit, a 30 year police career with the Metropolitan Police, which included a period of time with Metropolitan and City Police Company Fraud Departments.  In addition, White was the designated financial investigator on Operation Crevice the fertilizer plot and still the longest trial in UK Criminal History,  7/7 The Suicide Bombings of the London Transport Network in July 2005 and Operation Overt the Airliner Plot in 2006.  White is married with three children and holds a Master’s Degree in Fraud Management.

ACAMS Today: In your LE career what led you to participate in the terrorist and fraud units?

Grahame White: I looked at the benefits of being involved in fraud and the skills that you are taught as an investigator are transferable to the private sector. Law enforcement individuals with financial/fraud training and experience are still sought after and have a good reputation within the financial industry. The movement into terrorist investigations was a skill I further developed which focused on the use of analysis and f financial intelligence, which also proves to be another set of transferable skills. 

AT: You were involved in three historic cases in the UK. How did your career in LE prepare you as a financial investigator for your participation in those cases?

GW: The short answer is we refer to the investigators toolkit, that is the legislative and regulatory means by which a trained financial/fraud officer can obtain his intelligence/evidence from financial institutions and other reporting entities to build his road map of the crime or terrorist activity. Allied to the experience/instinct you develop as an investigator and as an LE officer makes for a good mix.  It is also important to have a desire for this type of work.

AT: As a fraud detecting expert, what are the most important lessons you have learned when dealing with fraudsters?

GW: The most important lesson in dealing with fraud is to make sure you look at all the detail, take your time and deal only with the facts. Use the skills as a financial investigator to examine in depth the lifestyle of the alleged suspect—it’s amazing what you can uncover. I never ceased to be amazed by stories and explanations that fraudsters come up with. Deal with the facts, and the nuisances will take care of themselves.

AT: What is your vision for Europe as head of European operations for ACAMS?

GW: I want ACAMS to grow in Europe. I have set a strategic plan that will be articulated to members and chapter boards across Europe as we develop.  My primary objectives are to increase certified members and the overall membership, develop and build on the excellent work done so far by conferences. My vision for enhancing and increasing attendance at the European conference is by having a more dynamic program, addressing concerns of the European financial crimes community, refreshing subject-matter expertise and expanding the speaker faculty with the addition of new talent.  Furthermore, we are looking to reach out to the whole European community with new locations for the European conference.

I also would like to introduce Quarterly Financial Crime Insights that reflect the essence of ACAMS. We will begin by delivering regionally in the UK, starting in Edinburgh in October and then expanding to Europe.  The message I want to deliver to potential members is that ACAMS is the most effective and competent support network.  This network includes me and the rest of the ACAMS staff who is willing to support, offer guidance and encouragement to all members.  Some of my objectives are as follows:

• Carry out a recruitment drive within law enforcement
• Bringing awareness to the personal professional development opportunities offered through the benefits of the ACAMS Certifications
• Introducing CPD Accreditation for the financial, legal, accountant sectors as well as looking to develop relationships with independent financial advisors, and consultants in the Fraud Financial Crime and Analytics fields.
• Developing partnerships with associations such as the BBA and ICAEW, and Law Society.

Finally, my personal message is that I want every ACAMS member in Europe to know that I am accessible through email and/or through my mobile phone and as such, I will make my contact information available to the members.

AT: What unique challenges does Europe face in its fight against financial crimes?

GW: First, bribery and corruption which require constant internal vigilance and an effective and robust management; second, measurable compliance processes particularly in the emerging markets (e.g., third party and beneficial ownership due diligence) and third, cybercrime and protection of data and finally, the need for good training and qualified staff.

AT: Can you provide some terrorist financing typologies and methodologies that you’ve seen? 

GW: In the UK we see a predominance of high yield, low-risk fraud perpetrated against the retail financial institutions, as well as charitable donations being siphoned off toward terrorist activity. This can be anything from family support to buying weapons. This methodology is prevalent in the UK, and has been replicated in other European countries (this includes credit card abuse) and it is usually at the preparation stage of training and travel as well as equipment purchases. We do not see Hawaladars being used to transfer funds as it is not culturally acceptable to hit on their own system of banking. In the intelligence phase of the terrorist plot the cells have a tendency to become self-supporting, procuring bomb making material and passing funds between themselves for lifestyle purchases. 

AT: What changes, if any, need to be made to improve public/private cooperation in Europe?

GW: I am strongly of the opinion that there needs to be greater information sharing between private and public sectors. I am sympathetic to reporting institutions requests for better quality feedback from LE to help them better understand typologies of fraud, etc. Also, the better the quality of feedback received from the LE, then the better quality of the SAR/STR being submitted by the financial institutions. The requirement as I see it is to involve the reporting institutions in the intelligence cycle.

AT: What is the single most important thing a financial institution can do to prevent terrorist financing? 

GW: Report any concern but be specific and accurate in the narrative of the SAR to allow for a more streamlined and quicker submission to LE for investigation.  Provide as much intelligence as possible in the body of the SAR, bio data, communication information, company names, emails, associates, phone numbers, etc. The requirement is for a concise linear narrative that emphasizes the concerns and criminality for quicker dissemination by law enforcement; however, this can only be achieved by effective feedback on the typologies and trends on criminal and terrorist activity by LE to the reporting sector.

AT: What was your proudest achievement at Scotland Yard?

GW: My proudest achievement at New Scotland Yard is the completion of thirty years of service. I had the privilege of working for the world's leading LE agency in two of its major investigative components, fraud and terrorism. 

Interviewed by: Karla Monterrosa-Yancey, CAMS, editor-in-chief, ACAMS, Miami, FL, USA, editor@acams.org