ACAMS Today Europe Digital is an online magazine with insightful and timely anti-money laundering/combatting the financing of terrorism-related content.
A subset of this publication is our Europe Express column, which covers anti-financial crime-related content with a regional focus in Europe from subject-matter experts.
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Birth of a Global Watchdog: The Egmont Group
In stark contrast to the cold day of June 9, 1995, the atmosphere at the Egmont-Arenberg Palace in Brussels was ablaze with tension and anticipation. As members of the Belgian financial intelligence unit (FIU), the Cellule de Traitement des Informations FinanciĂšres (CTIF-CFI) patiently awaited the arrival of the train that held 100 representatives from 24 nations and eight international bodies from the Financial Action Task Forceâs (FATF) plenary meeting in The Hague; they felt that they were venturing into uncharted territory.
EUâs Approach to Sanctions
Companies involved in transnational business are concerned about sanctions primarily because of the U.S. Office of Foreign Assets Control (OFAC), which is highly active in terms of enforcement and imposes large penalties on sanctions violators. Conversely, while the European Union (EU) has also been active in imposing sanctions, it has not been as effective regarding sanctions enforcement.
Stopping Cross-Border Illicit Financial Flows
ACAMS Today Europe Digital spoke to Grace Jackson and Maksym Markevych, who work for the Financial Integrity Group in the Legal Department of the International Monetary Fund (IMF), about their partnership with Denmark, Estonia, Finland, Iceland, Latvia, Lithuania, Norway and Sweden in a first-of-its-kind technical assistance project to strengthen the effectiveness of anti-money laundering/counter-terrorist financing (AML/CTF) frameworks.
Money Launderers for Hire: Antwerpâs Cocaine Dilemma
In 2021, Belgian authorities intercepted a colossal 89 metric tons of illicit drugs valued at 4.5 billion euros (approximately $4.8 billion) within the confines of Antwerpâs bustling port in what was known as Operation Sky ECC. Despite the successful achievement and the apprehension of 888 suspects, the stakeout only scratched the surface of an expansive drug trafficking web that has taken a grip on Belgium.
Captagon: A Dangerous Pill to Swallow
In early September 2022, Syriaâs Ministry of Interior released a video showing dozens of seized hummus bowls. A bowl is subsequently picked up and peeled with a knife, revealing that the bowls were concealing an illicit drug called Captagon. According to the Ministry, pills had been crushed and the resulting paste had been used to mold pottery-like dishes in an attempt to sneak the drug past authorities.
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Captagon: A Dangerous Pill to Swallow
In early September 2022, Syriaâs Ministry of Interior released a video showing dozens of seized hummus bowls. A bowl is subsequently picked up and peeled with a knife, revealing that the bowls were concealing an illicit drug called Captagon. According to the Ministry, pills had been crushed and the resulting paste had been used to mold pottery-like dishes in an attempt to sneak the drug past authorities.
Cleaning Up Dirty Money in the Art Trade
The art marketâs vulnerabilities to financial crime have recently become a growing concern in the U.S., Europe and the U.K. Increasingly, authorities have turned their attention to art market transactions, acknowledging thatâlike other high-end assetsâthe art trade is ripe for money laundering. Scrutiny has been expedited and heightened by the ongoing war in Ukraine.
Germanyâs New AML Authority and Its Uphill Battle
When Lisa Paus, a financial expert in Germanyâs Green Party, tried to identify the owners of the Kundamm-Karee âFĂŒrstâ project, she hit a wall. The approximately 635,071-square-foot urban area that would house office spaces, retail stores and art galleries at KurfĂŒrstendamm, one of Berlinâs most well-known avenues, had switched proprietors seven times in 2021, costing âŹ1.02 billion euros ($1.32 billion).
Human Trafficking in Times of Conflict
The trafficking of human beings increases dramatically in times of conflict, and the combination of conflict and migration leaves a significant number of unaccompanied migrant and refugee children at high risk of institution-related trafficking, as well as various forms of abuse and exploitation.
The Importance of Collaboration in CSE Investigation
Child sexual exploitation (CSE), child sexual abuse materials (CSAM) and child sex trafficking (CST) are serious crimes that adversely impact children being coerced or manipulated into engaging in sexual activity for financial gain. The ACAMS Today Back-to-the-Basics article, âBeyond The HeadlinesâA Real Look at Trends in CSAM and CST,â introduces and delves deeper into this topic and provides a classification for these heinous crimes.
Dissecting the Mafia: Apulia’s Sacra Corona Unita
The Italian criminal underworld is infamous for its Sicilian mobsters and Calabrian drug traffickers, but little is known of the âFourth Mafia,â or the Sacra Corona Unita (SCU). Sprung from the depths of Apuliaâs prison system, it makes up one of the major mafia groups in the country, along with Sicilyâs Cosa Nostra, Calabriaâs âNdrangheta and Campaniaâs Camorra.
Dissecting the Mafia: Campaniaâs Camorra
Campaniaâs Camorra, one of the four major Mafia groups in Italy, along with Sicilyâs Cosa Nostra, Calabriaâs âNdrangheta and Pugliaâs Sacra Corona Unita, is one of the most insidious and dangerous criminal organisations in the world.
Dissecting the Mafia: Sicilyâs Cosa Nostra
For the past 100 years, the mafiaâs brutal and lawless presence has influenced everything from pop culture to history, extending beyond Italyâs borders to impact crime around the world.
Dissecting the Mafia: Calabriaâs âNdrangheta
C alabria, the southern region of Italy referred to as the âtoeâ of the âboot,â is home to one of the most dangerous crime syndicates in the worldâthe âNdrangheta. Its ruthlessness has made it one of the major players in the international drug market, allowing the expansion of its criminal enterprise to encompass all of Italy and beyond.
The Emotional Consequences of Fraud
Beyond the financial cost, emotional harm is the most common impact of fraud, and it can exert a heavy emotional toll on its victims. The European Commission reported that 79% of fraud victims suffered emotionally, 24% suffered financially and 6% suffered physically.
Qatargate: Uncovering Corruption
Qatargate refers to European Parliament officials, lobbyists and their families who were allegedly involved in corruption, money laundering and organised crime, influenced by the governments of Qatar, Morocco and Mauritania. In December 2022, there were several arrests and searches affecting former and current members of the European Parliament, parliamentary assistants, nongovernmental organisation (NGO) representatives and even a trade union leader.
Have Sanctions Against Russia Prompted Commodity Laundering?
Sanctions can be effective if they are proportional to the strength of their enforcement and the unity of global efforts. EU sanctions against Russia, its oil and natural gas industry, are not an exception to this rule. Whilst many suggest that sanctions have worked as planned, the surfacing data reveals that much more collective work is needed.
Birth of a Global Watchdog: The Egmont Group
In stark contrast to the cold day of June 9, 1995, the atmosphere at the Egmont-Arenberg Palace in Brussels was ablaze with tension and anticipation. As members of the Belgian financial intelligence unit (FIU), the Cellule de Traitement des Informations FinanciĂšres (CTIF-CFI) patiently awaited the arrival of the train that held 100 representatives from 24 nations and eight international bodies from the Financial Action Task Forceâs (FATF) plenary meeting in The Hague; they felt that they were venturing into uncharted territory.
EUâs Approach to Sanctions
Companies involved in transnational business are concerned about sanctions primarily because of the U.S. Office of Foreign Assets Control (OFAC), which is highly active in terms of enforcement and imposes large penalties on sanctions violators. Conversely, while the European Union (EU) has also been active in imposing sanctions, it has not been as effective regarding sanctions enforcement.
Stopping Cross-Border Illicit Financial Flows
ACAMS Today Europe Digital spoke to Grace Jackson and Maksym Markevych, who work for the Financial Integrity Group in the Legal Department of the International Monetary Fund (IMF), about their partnership with Denmark, Estonia, Finland, Iceland, Latvia, Lithuania, Norway and Sweden in a first-of-its-kind technical assistance project to strengthen the effectiveness of anti-money laundering/counter-terrorist financing (AML/CTF) frameworks.
Money Launderers for Hire: Antwerpâs Cocaine Dilemma
In 2021, Belgian authorities intercepted a colossal 89 metric tons of illicit drugs valued at 4.5 billion euros (approximately $4.8 billion) within the confines of Antwerpâs bustling port in what was known as Operation Sky ECC. Despite the successful achievement and the apprehension of 888 suspects, the stakeout only scratched the surface of an expansive drug trafficking web that has taken a grip on Belgium.
Harmonisation of the EU AML Framework
Whilst the EUâs anti-money laundering (AML) directive has been in existence since 1991, the framework has continued to evolve over the past 30 years. The European Commission has implemented the Financial Action Task Force (FATF) recommendations whilst increasingly adopting its own standards and best practices to meet the political and economic requirements of its 27 member states.
Italy: The Mafiaâs Infiltration Into Healthcare
Organised crime has a triple interest in the direct and indirect management of health services in Italy. First, there is interest because of the huge amount of money that revolves around these services, which can guarantee large profits for gangs. Second, investment in health is a fairly easy way to launder the proceeds of illegal activities derived mainly from drug trafficking.
Russiaâs Ukraine Invasion Spurs on a United Europe
In 31 March, ACAMS was privileged to host the âAnti-Financial Crime SymposiumâBalticsâ in Vilnius. About 250 Lithuanian, Latvian and Estonian anti-financial crime (AFC) professionals from the private sector and government were delighted by the opportunity to meet face-to-face for the first time in more than two years.
ACAMS Germany Chapter: 2021 in Review
In 2021, the ACAMS Germany Chapter hosted five online events covering a range of emerging topics, such as environmental, social and governance (ESG) and decentralised finance (DeFi). In addition, it covered developments in some of the most crucial areas of anti-financial crime (AFC), such as sanctions and transaction monitoring.
ACAMS Malta Chapter: Virtually Building A Community From Zero
When we set out to build a new ACAMS Chapter in Malta more than two years ago, in December 2019, we were excited. Malta is a place that values connections and relationships, debate and education. At the time, Maltaâs national anti-money laundering/combatting the financing of terrorism (AML/CFT) framework was coming under the international spotlight following MONEYVALâs 2019 Fifth Round Mutual Evaluation Report on Malta.
Samar Pratt, CAMS-AuditâUK
Samar Pratt leads Exigerâs financial crime compliance advisory practise, specialising in audit and assurance. Since joining Exiger, Pratt has served as the deputy monitor on behalf of the US Department of Justice, and led independent examinations for the Financial Conduct Authority and the New York Federal Reserve board. In addition, she has helped clients to strengthen their financial crime compliance controls across the three lines of defence.
ACAMS Luxembourg Chapter: Continuous Growth and Looking Ahead
Located in proximity to political and financial âcentresâ Brussels and Frankfurt, Luxembourgâseat to several EU institutions, including the European Court of Justice of the European Union and the European Public Prosecutorâs Officeâoffers a dynamic scene for both private companies and public organisations.
ACAMS UK ChapterâA Short History in Time
In the last 10 years, the ACAMS UK chapter has become a force with which to be reckoned. Since its inception in 2011, the chapter board has comprised a stellar group of professionals, including veterans in law enforcement and the financial services industry.
Yuri Broodman, CAMSâNetherlands
Yuri Broodman is a proactive team player with 20 years of business experience in various functions. In addition, from 1999 to 2007, he served in the Royal Netherlands Navy. In 2014, Broodman began his compliance career in Luxembourg. His career advanced from senior compliance officer to country head of Financial Crime and Regulatory Compliance at HSBC.
Luiza Jarocka, CAMSâPoland
Luiza Jarocka, head of compliance for MoneyGram International, is responsible for customer investigations and regulatory filing of suspicious activity reports, suspicious transaction reports and customer transaction reports in over 30 jurisdictions.
Andrew Mackay, CAMSâMalta
Andrew Mackay is an independent AML/CFT compliance consultant currently engaged in the Caribbean, Malta and other international financial centres. Previously, Mackay was the head of Financial Crime Threat Mitigation for HSBC in Malta. This role involved identifying, understanding and mitigating the financial crime risks in Malta and transnationally through investigations, analytics and intelligence.
The Long and Winding Road to Anti-financial Crime Harmony
Music is an important part of many peopleâs lives. The first time I heard a live duo was on the playground in elementary school. I loved swinging and there were only a few swings available during recess for the entire school. Of course, if you were lucky to get one of those coveted swings, it always came with a duo concert from Justin and Scott singing songs from Metallica and Guns Nâ Roses at the top of their lungs.
Financial Risks Involving the Taliban Regime in Afghanistan
The Taliban takeover of power in Afghanistan in August 2021 presents the international community, including the financial industry, with a range of complex challenges. Not only are key stakeholders of the Taliban regime sanctioned by the United Nations Security Council (UNSC) and several governments, including the US, but the Taliban movement continues to maintain a close symbiotic relationship with al-Qaida.
EU-wide Rules for Crypto Assets
Crypto assets have given private individuals and groups the ability to access and provide a range of alternative financial services, which fall outside the scope of traditional banking, investments and payment servicesâ monopolies.
The Evolution of Social Fraud
Fraud can be simply described as the act of deception for personal gain. Acts of deception usually involve victims, either individuals or businesses. In most fraud occurrences, the primary motive and gain is financial. However, data has also become the primary target of fraudulent acts.
Matis MĂ€eker: Starting With a Clean Slate
ACAMS Today Europe editorial interviewed Matis MĂ€eker, head of the Estonian Financial Intelligence Unit (FIU) and a member of the MONEYVAL Bureau. MĂ€eker has been the evaluator and reviewer of many mutual evaluation reports conducted by MONEYVAL. He is also a member of the Estonian delegation to MONEYVAL and a member of the Heads of FIU of the Egmont Group.
Italy: The Mafiaâs Infiltration Into Healthcare
Organised crime has a triple interest in the direct and indirect management of health services in Italy. First, there is interest because of the huge amount of money that revolves around these services, which can guarantee large profits for gangs. Second, investment in health is a fairly easy way to launder the proceeds of illegal activities derived mainly from drug trafficking.
Lora von Ploetz: The New Face of Leadership
ACAMS Today Europe spoke with Lora von Ploetz, head of a Global Financial Crime Unit focusing on mitigating significant financial crime risks, proactive investigations, analytics and technology. She discusses the impact of Russian sanctions, challenges faced by European anti-financial crime (AFC) professionals and how she has been a mentor for women in AFC.
The Global Rise of Crypto-based Investment Scams
According to recent estimates, cryptocurrency-based crime reached a new all-time high in 2021, with 14 billion dollars of stolen funds, compared to 7.8 billion dollars in 2020. One of the most common ways to steal money from unsuspecting investors is the so-called ârug pull,â a practice whereby developers build what appears to be a legitimate cryptocurrency investment platform to lure investors in and steal their funds.
Metaverse: A Virtual World
The metaverse has been making headlines for the past few months since Facebook announced its rebranding to Meta. However, there is much more to the metaverse than Facebookâs version. The metaverse has actually been around for a few years now, and there is more than one single metaverse. The metaverse itself is a concept in its very early stages of development.
Institution-related Trafficking: Ukrainian Children at Risk
A month after the invasion of Ukraine, more than seven million people had been displaced as a direct result of the war, according to the International Organisation for Migration (IOM). The United Nations High Commissioner for Refugees (UNHCR) highlighted that most displaced people and refugees are women and children.
Central Bank Digital Currencies: The Doâs and Donâts
Monetary value has taken various forms over timeâbeef, salt, mother of pearl, amber, metal, paper, shells, etc. Today, there are two types of money issued by countries via their central banks: fiduciary money or fiat (money and banknotes) and scriptural money (checks and transfers).
The Role of ESG in Global Governance and the Supply Chain
Environmental crime is one of the largest criminal activity sectors in the world. There are many kinds of environmental crimes, including illegal emissions into the air, discharge of substances into water or soil, illegal trade in wildlife or ozone-depleting substances, as well as illegal shipments or rubbish dumping.
France: The Risks of Outsourcing AML Tasks
In todayâs world, decentralisation and globalisation are universally accepted values. Indeed, manufacturing a single pair of jeans involves multiple actors from around the world. âIt is estimated that for some [jeans], if you were to put each one of them end to end, the jeans would stretch in kilometres, one and a half times around the world (i.e. 65,000 km!).â
The Network-centric Approach: Helping Financial Crime Investigators to Combat Environmental Crimes
Environmental crime might sound new to financial crime professionals, but it is a challenge that investigators have wrestled with for years. Discussions about using open-source intelligence (OSINT) to prevent financial crime have long been underway. The Financial Crimes Enforcement Network (FinCEN) published articles urging organisations to consider the importance of environmental crime when doing business.
Paper Leaks: Their History and Impact
The Pandora Papers refers to a set of documents leaked from offshore services firms detailing tax evasion and avoidance practices, published by the International Consortium of Investigative Journalists (ICIJ) in October 2021. The ICIJ is a non-profit network that works with more than 100 media organisations and 280 journalists in more than 100 countries and shares sources, transcripts and videos of interviews.
Targeted Financial Sanctions and Their Interaction With Trusts
Several jurisdictions have recently put in place sanctions against individuals with ties to the Russian government, either directly or through enterprises. As targeted financial sanctions (TFS) place freezing measures on sanctioned individualsâ economic resources, some sanctioned individuals might inevitably seek ways to avoid these restrictions.
COVID-19 and The Sexual Exploitation of Children Online
The COVID-19 crisis triggered an unprecedented rise in the production and distribution of child sexual abuse material, child sexual exploitation material, live streams of child sexual abuse and, especially, self-generated sexual content involving children. During the onset of the pandemic, both children and child sex offenders were forced to stay home due to lockdown measures.
Putting Out Fire: A Global Collaboration Against Human Trafficking
Exploitation, vulnerable communities and trafficking have all existed throughout history. Even now, human trafficking is one of the fastest growing crimes worldwide and the exploitation of people is widespread and ingrained in society. Why it continues to prevail is a complex issue.
Latvia: Avoiding FATFâs Grey List
In 2017, findings by the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) served as encouragement and support for Latvia to initiate the needed changes to its anti-money laundering (AML), counter-terrorist financing (CTF) and counter-proliferation financing (CPF) system.
ACAMS Ireland Chapter: A Look Ahead
The ACAMS Ireland Chapter is celebrating its sixth anniversary! The chapter is excited to share its experience and that of the community in Ireland. New Players in the Irish Market Irelandâs financial sector is changing due to recent trends in digitising and democratising money, COVID-19 and an influx of firms impacted by Brexit.
ACAMS Netherlands Chapter: 10th Anniversary
Early in 2011, the current chair of the ACAMS Netherlands Chapter, Yevgeniya Balyasna-Hooghiemstra, was invited to help establish a chapter in the Netherlands, Belgium and Luxembourg (aka Benelux). Although she did not exactly know what a chapter was at the time, she was really excited about the opportunity to collaborate closely with ACAMS and with the other members in the Netherlands.
Andreia Amaro, CAMSâBragança, Portugal
Andreia Amaro is a compliance officer focused on anti-money laundering (AML) and counter-terrorist financing (CTF). She holds a degree in law from the Universidade de Coimbra in Portugal and has been a member of the Portuguese Bar Association since 2016.
Giuseppe Sollazo, CAMSâMilan, Italy
Giuseppe Sollazzo has over 10 years of experience in the anti-financial crime industry. His areas of expertise include anti-money laundering (AML), counter-terrorist financing (CTF), compliance and risk mitigation for international banking and financial services.
Migdalia Rojas, CAMSâFyllingsdalen, Norway
Migdalia Rojas has over 14 years of experience in the anti-financial crime (AFC) industry. She is a Spanish, English and French translator, as well as a lawyer from her homeland Venezuela. In addition, she holds an MBA from the University of Hull in the UK.
Uldis Upenieks, CAMSâRiga, Latvia
Since 2017, Uldis Upenieks has been a chief compliance officer and a member of the management board at Citadele Banka. He is responsible for the compliance function, including anti-money laundering (AML).
ACAMS Poland Chapter: Event Highlights
On 26 November 2020, the ACAMS Poland Chapter celebrated its second-year anniversary. Since it launched, the chapter has created the most significant community of anti-money laundering (AML) and financial crime compliance (FCC) professionals in Poland. The chapter has also kept a dynamic pace amid the COVID-19 pandemic.
Betrug und Angst: COVID-19 BetrugsfÀlle
Im April 2020 waren die deutschen Gesundheitsbehörden verblĂŒfft, als sie entdeckten, dass medizinische Masken im Wert von 2,4 Millionen Euro verschwunden waren. Es wurden anscheinend zehn Millionen Masken von zwei rechtmĂ€ssigen Unternehmen in ZĂŒrich und Hamburg bestellt, die wiederum eine in Spanien registrierte Webseite kontaktierten, um die benötigten Masken zu beziehen, als die Lieferung nicht eintraf.
Investmentfonds und GeldwÀscheprÀvention
Angesichts der vielen GeldwĂ€scheskandale und Ermittlungen im Bankensektor schleusen GeldwĂ€scherinnen und GeldwĂ€scher zunehmend illegale Gelder durch die Investmentfonds-Branche, die erwiesenermaĂen fĂŒr die Platzierung, Umschichtung und/oder Integrationsphasen von GeldwĂ€sche anfĂ€llig ist.
Fraude et peur : les escroqueries de la COVID-19
En avril 2020, les autoritĂ©s sanitaires allemandes ont Ă©tĂ© dĂ©concertĂ©es de dĂ©couvrir que des masques mĂ©dicaux dâune valeur de 2,4 millions dâeuros avaient disparu. Dix millions de masques avaient apparemment Ă©tĂ© commandĂ©s Ă deux sociĂ©tĂ©s de Zurich et de Hambourg, qui ont Ă leur tour contactĂ© un site web enregistrĂ© en Espagne pour se procurer les masques nĂ©cessaires, lesquels nâont jamais Ă©tĂ© livrĂ©s.
Dan Benisty : la compliance comme une ambition personnelle
Dan Benisty est responsable conformitĂ© lutte contre le blanchiment de capitaux et le financement du terrorisme (LBC/FT) pour lâEurope du Nord auprĂšs de lâentreprise de transfert dâargent, Western Union. Depuis 2013, il est co-fondateur et prĂ©sident du Chapitre France de lâACAMS ainsi que co-directeur du diplĂŽme universitaire du chargĂ© de conformitĂ© LBC/FT, proposĂ© par lâUniversitĂ© Paris-Saclay.
Fear Factor
If you ask me about fear, one experience leaps out in my lifeâthe first time I went bungee jumping. I went with a group of friends and each of us paid for six jumps. Standing atop that platform awaiting my first jump was quite intimidating. I have never been afraid of heights, but the idea of jumping into the air with only a harness attached gave me significantly more anxiety than I had anticipated.
Egmont Admonition: A Reminder That AML Can Be Misused
I write often and hopefully about the rising acceptance throughout the world of anti-financial crime standards. But it turns out global anti-money laundering and counter-terrorist financing (AML/CTF) standards are a little like âThe Forceâ in the Star Wars universe: there is a light (good) side and, as adopted and implemented by some governments, a dark side.
Sanctions: OFAC Penalties on European Companies
The relationship between the US and the EU has undoubtedly been friendly. However, the recent sanctions regime implemented by the Office of Foreign Assets Control (OFAC) of the US Treasury Department has created friction with the EUâs blocking statute. Under OFACâs sanctions regime, EU companies with US touchpoints are mandated to comply with US sanctions.
The AML Implications of the Human Egg Trade
The money laundering process typically involves the furtive introduction of illegitimate funds into the legitimate financial system and the steps taken by bad actors to distance themselves from the illegal sources of these funds. When the crime is understood, the work of anti-money laundering (AML) professionals is often straightforward, but what is their role when it is unclear if the funds are derived from criminal means because laws are ambiguous?
Cryptocurrency Regulations: Finding the Right Balance
There are various ideas about cryptocurrencies; some claim that they are a Ponzi scheme, a scam or a bubble, others say they are the future. What exactly are they? Cryptocurrencies are like fiat money, but they do not have a physical presence and more importantly, they are not typically issued nor controlled by countries; except for the closed source (or proprietary) cryptocurrencies.
Brexit Deal: Impacts in the Fight Against Financial Crime
After years of intense negotiations, two general elections and a third prime minister, the UK finally secured a Brexit agreement with the EU on 24 December 2020, officialising its exit from the bloc. The Brexit deal, formally known as The EU-UK Trade and Cooperation Agreement (TCA) sets out the preferential arrangements in areas such as trade in goods and services, law enforcement and judicial cooperation in criminal matters.
Dan Benisty: Compliance as a Personal Ambition
Dan Benisty is the director of compliance for the anti-money laundering and counter-terrorist financing (AML/CTF) program for the Northern European region at Western Union. Benisty is a co-founder and president of the ACAMS France Chapter, which he has chaired since its establishment in 2013. In addition, he is joint director of the AML/CTF compliance degree program at Université Paris-Saclay.
Fraud and Fear: COVID-19 Scams
In April 2020, German health authorities were baffled when they discovered that 2.4 million euros worth of medical masks disappeared. Ten million masks were apparently ordered from two legitimate companies in Zurich and Hamburg, which in turn contacted a website registered in Spain to procure the masks needed when the delivery failed to arrive.
Investment Funds and AML
Given the increase in money laundering scandals and investigations in the banking sector, money launderers have started to funnel illicit funds through the investment fund industry, a channel proven to be susceptible to the placement, layering and/or integration phases of money laundering.
AML: The Risk of Investor Citizenship Schemes in Europe
The investor citizenship or âgolden passportâ scheme in Europe became a hot topic of discussion after an investigation by Al-Jazeera in August 2020. Al-Jazeeraâs investigative unit published the âCyprus Papers.â These leaked documents revealed how 2,500 peopleâincluding political figures, convicted criminals and money launderersâpaid for their Cypriot citizenship through the notorious Cyprus Investment Programme (CIP).
The FinCEN Files and the Risk of Correspondent Banking
The Financial Crimes Enforcement Network (FinCEN) Files investigation is the latest publication by the International Consortium of Investigative Journalists (ICIJ) that reveals how certain flows of funds are suspected to be connected to financial crime, money laundering, terrorist financing and/or corruption.
Die FinCEN Files und die Risiken des Korrespondenzbankges chÀftes
Die Recherche Financial Crimes Enforcement Network (FinCEN) Files ist die jĂŒngste Publikation des Internationalen Konsortiums Investigativer Journalisten (ICIJ) ĂŒber Geldströme, die vermutlich in Verbindung zu FinanzkriminalitĂ€t, GeldwĂ€sche, Terrorismusfinanzierung und/oder Korruption stehen.
Sanctions : amendes de lâOFAC contre les entreprises europĂ©ennes
Les relations entre les Ătats-Unis et lâUnion europĂ©enne (lâUE) sont sans aucun doute amicales. Toutefois, le rĂ©gime de sanctions rĂ©cemment mis en Ćuvre par le Bureau du contrĂŽle des avoirs Ă©trangers (OFAC, pour Office of Foreign Assets Control) du TrĂ©sor amĂ©ricain a crĂ©Ă© des frictions avec le rĂšglement de blocage de lâUE.
Rebekah Lisgarten: You Canât Stop What You Canât See
ACAMS Today Europe interviewed Rebekah Lisgarten, director of operations at STOP THE TRAFFIK, to discuss the organisationâs achievements in combatting human trafficking (HT) and emerging HT trends.
ACAMS Germany Chapter: 2019 in Review
The ACAMS Germany Chapter hosted a variety of engaging events throughout 2019. The year began with an event on anti-financial crime and fintech in January. Experts from German fintech Fidor Bank, investment bank Baader Bank and UniCredit discussed fintech company challenges in implementing adequate financial crime prevention frameworks and the importance of a tailored risk assessment approach.
Animaux Sauvages : Le Commerce Illégal Sous-Déclaré
Bien que les enquĂȘtes sur la lutte contre blanchiment de capitaux (LBC) soient en constante Ă©volution, une source majeure de profit illĂ©gal Ă lâĂ©chelle internationale demeure largement inconnue : le trafic dâespĂšces sauvages. Le trafic dâespĂšces sauvages est un commerce illĂ©gal majeur et un crime environnemental qui devrait gĂ©nĂ©rer entre sept et 23 milliards de dollars par an.
RGPD : ConfidentialitĂ© vs EnquĂȘtes
La Commission europĂ©enne est tenue de soumettre au Conseil europĂ©en, avant le 25 mai 2020, un rapport examinant lâimpact de lâarticle 97 du RĂšglement gĂ©nĂ©ral sur la protection des donnĂ©es (RGPD) de lâUE. Dans le cadre de lâexamen, la Commission doit examiner lâapplication et la fonction dâune sĂ©rie de dispositions, notamment celles relatives au transfert international de donnĂ©es Ă caractĂšre personnel.
Karl-Johan Karlsson, CAMS-AUDIT â Copenhagen, Denmark
Karl-Johan Karlsson is currently the head of compliance at Handelsbanken in Denmark. He holds a Master of Laws degree from the University of Liverpool. He is a Certified Anti-Money Laundering Specialist (CAMS) and was among the first in Europe to earn the Advanced CAMS-Audit Certification from ACAMS.
In This Together
Seemingly contradictory trends are unfolding in the EU as I write this for the May-June issue of ACAMS Today Europe. A leaked European Commission report is proposing the creation of an uber-financial intelligence unit to coordinate and set standards for the 27 member statesâ financial intelligence units (FIUs).
Wild Kingdom
I have recently found myself with time on my hands, as have we all during the COVID-19 pandemic. While checking my social media feed, I came across an article by National Geographic that caught my eye for two reasons. The article was about the plight of the northern white rhinoceros, an incredibly endangered species.
EU-UK Sanctions Post-Brexit: Compliance Preparations and Deliberations
The UK left the EU on 31 January 2020, and has now entered an 11-month transition period. Whilst most of the ongoing press coverage is focused on efforts to reach a trade deal, other issuesâincluding future co-operation arrangements on security and law enforcementârequire negotiation and agreement.
One Year with the ACAMS Switzerland Chapter
The ultimate objective of the ACAMS Switzerland Chapter is to become part of ACAMSâ global network whilst addressing the specific challenges of the local environment. The chapter strives to broaden information and expertise sharing across industries in Switzerland.
Sven Eisermann, CAMSâBerlin, Germany
Sven Eisermann is head of the anti-money laundering (AML) department and deputy money laundering reporting officer (MLRO) at Deutsche Kreditbank AG (DKB) in Berlin. DKB is one of the top 20 banks in Germany to offer online banking services for private customers as well as modern banking solutions for selected business customers focussed on a sustainable business strategy.
Lorenzo De La Calle Jimenez, CAMSâMadrid, Spain
Lorenzo De La Calle JimĂ©nez has more than 30 years of experience in the financial services sector with a focus on anti-money laundering/counter-terrorist financing (AML/CTF). De La Calle JimĂ©nez began working for Western Union in 2013, holding several roles on the companyâs anti-money laundering (AML) compliance team.
Wildtiere: ien wenig beachteter Schwarzmarkt
Obwohl sich Ermittlungsverfahrenen zur BekĂ€mpfung von GeldwĂ€sche (AML) stĂ€ndig weiterentwickeln, bleibt eine Hauptquelle fĂŒr illegale Erlöse auf internationaler Ebene weitgehend unbekanntâder Handel mit Wildtieren. Der Handel mit Wildtieren ist ein bedeutender Schwarzmarkt und ein Umweltverbrechen, das jĂ€hrlich schĂ€tzungsweise zwischen sieben und 23 Milliarden US-Dollar generiert.
Borderless Cryptocurrency, Borderless Regulation
In 2008, the pseudonymous Satoshi Nakamoto published the bitcoin white paper describing a cryptocurrency free from the control of governments or banks. Twelve years later, there are over 2,000 cryptocurrencies, but Nakamotoâs libertarian vision has collided with the realities of regulation. According to Chainalysis, a New York-based blockchain-tracing company, over 90% of cryptocurrency transactions by volume pass through centralised intermediaries such as exchanges.
GDPR: Privacy vs Investigations
The European Commission is required to submit a report reviewing the impact of Article 97 of the EUâs General Data Protection Regulation (GDPR) to the European Council by 25 May 2020. As a part of the review, the Commission must examine the application and function of a series of provisions, not least those pertaining to the international transfer of personal data.
To Detect Financial Crime, Machine Learning Requires the Human âTouchâ
The application of big data and machine learning in anti-money laundering (AML) transaction monitoring (TM) programs is undeniably vast. Over the past five years, financial institutions (FIs) have assessed how they could implement and benefit from machine learning capabilities.
EUâs Public Beneficial Ownership Registers Are a Game Changer
Identifying beneficial owners with a satisfactory level of certainty has been a manual and often fastidious task for know your customer analysts and compliance officers. Issues vary from deciphering poorly scanned articles of association, to the design, collection and verification of beneficial ownership statement forms as well as pencil-drafted ownership diagrams.
Germany Brings Gatekeepers Into AML Framework
Allegations of the real estate market being used for money laundering (ML) and tax evasion have made headlines in the German media. This has resulted in heated political debates across the political spectrum, particularly, debates on the role of intermediaries. Notaries have been accused by various political parties of neglecting their responsibility in the fight against ML in the real estate sector.
Wildlife: The Underreported Illegal Trade
Although anti-money laundering (AML) investigations are ever evolving, one major source of illegal profit internationally remains largely underreportedâwildlife trafficking. Wildlife trafficking is a major illegal trade and an environmental crime that is estimated to generate between seven billion US dollars and 23 billion US dollars annually. The number of critically endangered species and the involvement of poachers is well documented.
New Technologies: The Emerging Terrorist Financing Risk
Technical innovations in communications and in the financial sector have not been ignored by terrorist groups and organisations. Instead, these innovations have added to terrorist capabilities. Since the rise of the Islamic State of Iraq and the Levant (ISIL), a significant body of research has been conducted on their misuse of communications technology.
Keeping Europeâs Free-Trade Zones Safe for AML
Free-trade zones (FTZs) pose a regulatory contradiction for governance. Governments, whether those of traditional nation-states or of supranational entities such as the EU, consciously restrict their own powers of taxation, oversight and regulation to facilitate economic growth and innovation in areas designated for free trade. By their nature, modern FTZs appear to be built upon irony.
Schutz von Europas Freihandelszonen vor GeldwÀsche
Freihandelszonen konfrontieren eine Vielzahl an Governance-BemĂŒhungen mit einem Widerspruch. Die Regierungen, seien es die traditioneller Nationalstaaten oder supranationaler Einheiten wie der EU, schrĂ€nken ihre eigenen Befugnisse in Bezug auf Besteuerung, Aufsicht und Regulierung bewusst ein, um in den fĂŒr den Freihandel bestimmten Gebieten Wirtschaftswachstum und Innovation zu fördern. Moderne Freihandelszonen scheinen ihrem Wesen nach auf Ironie zu basieren.
Why Does the Computer Say No? Algorithm Transparency for AFC Systems
When the phrase âcomputer says noâ was first used in âLittle Britainâ, a British comedy show from over a decade ago, it resonated with many because it reflected the widespread use of algorithms in day-to-day decision-making. Carol, a character played by David Walliams, a bank worker and later holiday rep and hospital receptionist, always responded to a customerâs request by typing it into her computer and responding with âcomputer says noâ, even to the most reasonable requests.
Deutschland setzt Gatekeeper im Kampf gegen GeldwÀsche ein
VorwĂŒrfe, der Immobilienmarkt werde fĂŒr GeldwĂ€sche (GW) und Steuerhinterziehung genutzt, haben in den deutschen Medien fĂŒr Schlagzeilen gesorgt. Dies hat zu heftigen politischen Debatten im gesamten politischen Spektrum gefĂŒhrtâinsbesondere zu Debatten ĂŒber die Rolle der Vermittler.
La Mondialisation de la Justice Négociée : Le Cas Français
La justice nĂ©gociĂ©e est un accord passĂ© avec lâautoritĂ© de supervision par lequel une sociĂ©tĂ© objet dâune enquĂȘte pour dĂ©linquance Ă©conomique et financiĂšre accepte de reconnaĂźtre des Ă©lĂ©ments de fait sans reconnaĂźtre sa culpabilitĂ©, de sâacquitter de sanctions financiĂšres, de compenser les victimes et de se soumettre Ă des obligations de compliance destinĂ©es Ă prĂ©venir la commission dâinfractions futures, en contrepartie de lâextinction des poursuites Ă son encontre.
Fintech: Friend or foe to anti-financial crime?
Fintechs are digital bank accounts and e-wallet services. There are more and more digital players in the market offering payment accounts, money pots or remittances services. What is new is that end-user adoption is growing quickly too. There is not a week without the media mentioning that challenger banks (aka âneo banksâ) like Monzo, Revolut or N26 are increasingly enrolling more and more customers.
Emerging Sanctions Challenges for Global Counter-Terrorism
With the attack on the village of Baghouz near the border between Syria and Iraq, Islamic State (IS) is about to lose the last territorial stronghold in the Middle East. This will end the recent tragic history of control over territory in the region from this terrorist organisation.
SARs Analysis on the Criminal Use of the Gaming (Casino) Sector
Arecent report written by the Metropolitan Police Service (MPS) examined the link between criminality and gambling. The MPS report analysed 250 suspicious activity reports (SARs) submitted by the gaming (casino) sector and other reporting sectors. Casinos are referenced between the 1 of January 2017 and the 30 of June 2017 within the MPS.
Handelsbasierte GeldwĂ€scheâ Risikofaktoren und Sorgfaltspflichten
Das seit dem 30. November 1993 in Deutschland geltende Gesetz ĂŒber das AufspĂŒren von Gewinnen aus schweren Straftaten (GeldwĂ€schegesetzâGwG) wurde zum 21. August 2008 neu gefasst und spĂ€ter durch das Gesetz zur Optimierung der GeldwĂ€scheprĂ€vention (GeldwĂ€scheoptimierungsgesetzâGwOptG) geĂ€ndert, welches am 29.
Liaisons Dangereuses: 5AMLD et EDD
La cinquiĂšme Directive anti-blanchiment de lâUnion europĂ©enne (5AMLD), entrĂ©e en vigueur le 9 juillet 2018, devra ĂȘtre mise en oeuvre par les Ătats membres dâici janvier 2020. Les entreprises affectĂ©es par cette nouvelle directive, les entitĂ©s concernĂ©es, sont confrontĂ©es Ă de nouveaux dĂ©fis en raison des modifications pertinentes de la quatriĂšme directive anti-blanchiment de lâUE (4AMLD) de 2015 (mise en oeuvre en 2017).
Fintech : Ami ou Ennemi du Crime Anti-Financier ?
Les fintechs sont des comptes bancaires numĂ©riques et des services de portefeuilles numĂ©riques. Un nombre croissant dâacteurs numĂ©riques propose des comptes de paiement, des fonds monĂ©taires ou des services de virement dâargent. Ce qui est nouveau, câest que leur adoption par les utilisateurs finaux croĂźt aussi rapidement.
Les Nouveaux Défis Posés par la Lutte Anti-Terroriste Internationale
Avec lâassaut du village de Baghouz, prĂšs de la frontiĂšre entre la Syrie et lâIrak, lâĂtat islamique est en passe de perdre son dernier bastion territorial au Moyen-Orient. Ainsi se terminera lâhistoire rĂ©cente tragique du contrĂŽle territorial, dans la rĂ©gion, exercĂ© par cette organisation terroriste.
Paradis Fiscaux, Enfer de la Fuite des Capitaux du Continent Africain
Paradis fiscaux, enfer des peuples africains » titrait en avril 2016, en plein scandale des Panama Papers, le journal burkinabĂ© le Pays. La dĂ©finition mĂȘme de paradis fiscal laisse Ă dĂ©battre. La notion mĂȘme de « fiscalitĂ© » dans ce contexte, et prise isolĂ©ment, nâa de sens que si elle peut ĂȘtre associĂ©e Ă ce que des spĂ©cialistes reconnus tels que Christian Chavagneux, Eric Vernier ou Gabriel Zucman qualifient de paradis bancaires, ou encore de paradis judiciaires.
Riskante GeschÀfte: 5AMLD und die verstÀrkte Sorgfaltspflicht
Die fĂŒnfte Anti-GeldwĂ€sche-Richtlinie der EuropĂ€ischen Union (5AMLD) wurde am 9. Juli 2018 verabschiedet und muss bis zum Januar 2020 von allen EU-Mitgliedstaaten umgesetzt werden. Von der neuen Richtlinie betroffene Unternehmen, sogenannte Verpflichtete, mĂŒssen sich mit neuen Herausforderungen auseinandersetzen, die aus den relevanten Ănderungen der vierten Anti-GeldwĂ€sche-Richtlinie der EuropĂ€ischen Union (4AMLD) aus dem Jahr 2015 (umgesetzt 2017) hervorgehen.
Fintech: Freund oder Feind bei der Aufdeckung von FinanzkriminalitÀt?
Fintechs sind Anbieter digitaler Bankkonten und E-Wallets. Eine zunehmende Anzahl von Marktakteuren bietet Zahlungskonten, Geldtöpfe oder Ăberweisungsdienste auf digitaler Grundlage an. Neu ist die Tatsache, dass auch die Akzeptanz bei Endbenutzern rapide steigt.
Ein Sammelsurium von Vorschriften
Blockchain-Technologie bietet eine breite Palette von Lösungen, die herkömmliche GeschĂ€ftsmodelle in Frage stellen. Diese Innovation bedarf jedoch aktualisierter Governance-Richtlinien, um die Effizienz mit der öffentlichen Sicherheit in Einklang zu bringen. Blockchain-Technologie kann autonomen Benutzern ermöglichen, Vermögen selbststĂ€ndig zu ĂŒberweisenâschnell, weltweit, jederzeit und ohne ZwischenhĂ€ndler.
Sandijs VectÄvs, CAMSâRiga, Latvia
After 15 years in the financial sector, Sandijs VectÄvs returned to law enforcement in the area of financial intelligence. Prior to managing the analytical compartment of the Latvian financial intelligence unit, VectÄvs gained professional experience in various fields.
Audrey Milesi, CAMSâNeuheim, Switzerland
Audrey Milesi lived and worked in Austria, Germany and London before moving to Switzerland in 2007. She began her career as an external auditor before moving to transaction services/mergers and acquisitions in the Big Four and transitioning into the industry. She led global financial compliance at the agrochemical company Syngenta and then moved to eBay to lead financial compliance for Europe/rest of the world.
Katarina Cook, CAMSâLondon, UK
Katarina Cook works as head of compliance and money laundering reporting officer for Europe Arab Bank in London. With a degree in Russian and political science, the move into the financial industry may not have seemed like the obvious choice for Cook.
Annika Brunned, CAMSâStockholm, Sweden
Annika Brunned is a compliance officer at Handelsbanken and head of the compliance international department covering Handelsbanken branches in Germany, Luxembourg, the Baltics, Poland, Singapore, Hong Kong, China and the United States. Brunned is an anti-money laundering (AML) compliance and financial crime prevention professional with over 30 years of practical experience within business, IT development and compliance at Handelsbanken.
Celebrating the ACAMS Cyprus Chapter
The ACAMS Cyprus Chapter recently celebrated its third birthday at a great venue in Nicosia! The special networking event hosted a number of members, regulators, law enforcement, as well as friends and supporters of the chapter.
The chapter was formed in November 2015 by a group of anti-money laundering (AML) and compliance enthusiasts with the support of ACAMS.
Prost to the ACAMS Germany Chapter
The Association of Certified Anti-Money Laundering Specialists (ACAMS) launched its Germany Chapter in late 2016. Since then, the chapter has hosted approximately 20 events across the country at its main hubs in Berlin, Frankfurt and Munich.
Risky Business: 5AMLD and EDD
The Fifth European Union (EU) Anti-Money Laundering (AML) Directive (5AMLD) which entered into force on the 9 of July 2018, must be implemented by the EU member states by January 2020. Firms affected by the new directive, obliged entities, face new challenges resulting from the relevant amendments to the Fourth EU AML Directive (4AMLD) of 2015 (implemented in 2017).
An Inspection of the Real Estate Sector in Germany
Germanyâs real estate industry is one of the largest economic sectors of the country, with 817,000 companies and around 3 million registered employees in 2017. In 2016, the entire sector was valued at around âŹ500 billion, representing a contribution of 18.2 percent to the growth of the entire economy.
The Rise of Cloud in Compliance
The last 18 years have seen financial institutions (FIs) create and deploy money laundering detection and prevention defences in response to regulatory demands. The means by which FIs achieve this task have stayed the same for decades. Institutions will go to the market, scan providers with solutions, select and purchase one, deploy it on an on-premises infrastructure and then run the solution.
The Intersection of AI in Financial Crime Compliance
Artificial intelligence (AI) is the latest technology to take the compliance community by storm when it comes to reducing false alerts in both anti-money laundering (AML) and international sanctions screening programs. As European institutions begin to explore these technologies, many institutions are finding that the results do not always meet expectations.
A Smorgasbord of Regulations
Blockchain technology offers a wide array of solutions that challenge traditional business models but this innovation needs updated governance policies to balance efficiency and public safety. Blockchain technology can allow for autonomous users to transfer wealth quickly, worldwide, at any time and without any middlemen using its heretofore most successful use caseâvirtual currencies.
Renaissance
At 19 years old, I set out on an adventure and lifelong dreamâto see Europe. Armed with my backpack and everything I thought necessary to survive a six-week excursion to the continent, I began visiting country-after-country. I learned from this thrilling adventure that Europe was more than what I had imagined and studied in college.
Catch the Bad Guys, Avoid a Penalty: Can compliance have it all?
Welcome to the first issue of ACAMS Today Europe. ACAMS Today launched in 2002 as a membership benefit of a newly formed United States-based association of anti-money laundering (AML) professionals. Today, the Association of Certified Anti-Money Laundering Specialists (ACAMS) is a global association of 73,000 members, and counting.