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Using RegTech To Enhance the Fight Against Financial Crime

Have you heard these common myths about anti-money laundering technology solutions? Myth 1: Anti-money laundering technology solutions are only necessary for financial institutions. Myth 2: Anti-money laundering technology solutions are too complex and expensive for small businesses. Myth 3: Anti-money laundering technology solutions can eliminate the need for manual compliance efforts.

I recently had the opportunity to visit with  Matt DeLauro, the Chief Revenue Officer at SEON, to explore these and other questions. (You can listen to the episode on Innovation in Compliance.) We considered the impact of real-time detection services and the importance of breaking through traditional data silos for a robust approach to fraud prevention and regulatory compliance. We also considered security measures such as device fingerprinting, the evolution of Suspicious Activity Reports, and the future landscape of compliance and anti-fraud efforts, and this episode offers a wealth of knowledge for compliance practitioners and professionals.

We also considered the critical importance of Anti Money Laundering (AML) regulations, particularly in the wake of increased sanctioned activities within European banking systems. Regulatory bodies emphasize the need for heightened AML efforts in the financial industry to combat money laundering and ensure compliance. Machine learning emerges as a key tool in detecting anomalies and potential money laundering attempts, with companies like SEON at the forefront with their integrated machine learning algorithms.

How can compliance professionals stay ahead of increasingly sophisticated money launderers and fraudsters? Financial crimes are evolving rapidly, but innovative RegTech solutions give compliance teams new tools. One interesting approach is to leverage device fingerprinting for fraud prevention. Device fingerprinting analyzes device metadata like location, typing patterns, and orientation to catch real-time account takeovers and bot attacks. By gathering intelligence on the device, compliance teams can identify suspicious access attempts and stop fraudsters.

Moreover, detecting and preventing fraudulent activities necessitates monitoring anomalous behaviors, such as unusual device access or IP addresses. Utilizing device fingerprinting data, behavioral biometrics, and machine learning algorithms can help identify patterns of fraudulent activities and enable real-time fraud detection to thwart fraudulent transactions instantly.

Another approach is through scaling monitoring with machine learning. This is because reviewing transactions manually is hugely time-intensive and limits scalability. Machine learning models overcome this by continually improving detection rates and reducing reliance on large manual review teams. Such an approach can identify complex schemes that rules-based systems miss and enable businesses to expand without compromising compliance. Continuously training machine learning models to enhance detection capabilities and prevent fraud in real time can aid in fraud detection and prevention. By feeding back labeled data on identified fraud or money laundering attempts into the machine learning algorithms, companies can improve detection accuracy over time.

This approach can be enhanced by unifying siloed data sources (this is the converse of how the Department of Justice presented this to compliance professionals, of breaking down data silos.) Centralizing compliance data from across departments gives investigators a holistic view of risk. This prevents the need to manually compile relevant information from separate systems, speeding up reviews and providing broader context.

Another financial crime protection strategy is to generate SARs automatically. This approach uses large language models, which can auto-generate the lengthy suspicious activity reports (SARs) regulators require. Rather than investigators manually piecing together all the details over hours, smart software reduces it to a few clicks, saving significant time and effort. Automation has revolutionized the generation of Suspicious Activity Reports, reducing the time spent on investigations and increasing efficiency. Centralized data and machine learning capabilities are crucial for better detecting potential fraudulent activities and streamlining the reporting process.

Leading compliance teams are embracing RegTech solutions to strengthen financial crime defenses in the face of growing threats from organized fraud rings and money laundering networks. The future will require even more agility to counter emerging criminal tactics. In the evolving landscape of financial crimes, with fraudsters leveraging sophisticated techniques and interconnected networks to bypass traditional controls, companies must adapt and innovate their fraud and compliance strategies to stay ahead of the curve in combating financial crimes. To drive this point home, DeLauro encapsulates the urgency and necessity for adaptive anti-money laundering measures with the following: “Companies that have a static or maybe a long-standing permanent set of controls around fraud and compliance get figured out by the fraudsters and the money launderers very quickly.”

As AML regulations take center stage as a national security priority, the podcast episode underscores the pivotal role of automation, machine learning, and continuous innovation in strengthening AML efforts and safeguarding financial ecosystems against fraudulent activities. Matt DeLauro’s insights shed light on the dynamic landscape of financial crimes and the imperative for organizations to embrace proactive prevention strategies to combat money laundering effectively.

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Innovation in Compliance

Innovation in Compliance: Staci Wright on Compassionate Workplace Solutions – The Heart Profit Movement

Innovation comes in many forms, and compliance professionals need to not only be ready for it but also embrace it. Today, I visited Staci Wright, a leader in the heart-profit movement.

Staci Wright is a seasoned entrepreneur with a diverse portfolio of six successful businesses, ranging from service-based to product-based ventures, established over the past two decades. Her perspective on the “heart profit movement” is rooted in her belief in the power of compassion, care, and connection in the workplace to not only enhance productivity but also address important societal issues.

This perspective is born from her experience leading “IP2Market,” a company that merges manufacturing patented products with a focus on building brands that prioritize employees’ welfare.

As the founder of the Heart Profit movement, Staci has implemented initiatives like onsite childcare, meals, and mental health coaching in her workplaces, embodying her view that a supportive environment allows employees to flourish rather than merely survive. This approach to business, she believes, fosters a more compassionate era where profit does not come at the expense of employee care.

Key Highlights:

  • Footrest-Inspired Self-Care Products for Bath Time
  • Compassionate Workplace Culture Initiative
  • Employee Wellbeing Initiatives in Manufacturing
  • Cultivating Compassionate Work Environments for Success
  • Compassionate Workplace Solutions: Profit with Heart

Resources:

Staci Wright on LinkedIn 

Heart Profit

Tom Fox

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Daily Compliance News

Daily Compliance News: April 16, 2024 – The Workplace Retaliation Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • The corruption case that rocked Singapore.  (BBC)
  • An NCAA hoops bribery informant dies. (ESPN)
  • The truth social auditor quits. (FT)
  • How to fight workplace retaliation. (WaPo)

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Compensation Incentives and Clawbacks

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we consider what the DOJ has done in terms of emphasizing financial incentives and penalties for compliance.

 

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Uncovering Hidden Risks

Ep 12 – Cloud Security Posture Management: Top Risks and Best Practice Solutions

Drew Nicholas, Microsoft Principal Security Global Black Belt, joins Erica Toelle and guest host Daniela Villarreal, Sr. Product Marketing Manager for Microsoft Defender for Cloud, on this week’s episode of Uncovering Hidden Risks. Drew has spent eight-plus years at Microsoft in different roles. These roles include working for Microsoft’s consulting services, Microsoft’s customer-facing Incident Response team, and his current position. Drew, Erica, and Daniela provide insight into hidden risks in cloud-native apps to help customers gain visibility and control of their cloud security posture and take a risk-based approach to proactive cloud security.

In This Episode You Will Learn:

  • How cloud security posture fits into the big picture of security
  • Qualities organizations should look for in a cloud security posture management tool
  • How different platforms can help strengthen cloud security posture

Some Questions We Ask:

  • Regarding cloud-native application development, what security trends have you seen?
  • Why is cloud security posture so important?
  • What risks can a unified security posture management approach help address?

Resources:

View Drew Nicholas on LinkedIn

View Daniela Villarreal on LinkedIn

View Erica Toelle on LinkedIn

Related Microsoft Podcasts:          

Listen to: Afternoon Cyber Tea with Ann Johnson 

Listen to: Security Unlocked

Listen to: Security Unlocked: CISO Series with Bret Arsenault

Discover and follow other Microsoft podcasts at microsoft.com/podcasts

Connect with the Compliance Podcast Network at:

LinkedIn: https://www.linkedin.com/company/compliance-podcast-network/
Facebook: https://www.facebook.com/compliancepodcastnetwork/
YouTube: https://www.youtube.com/@CompliancePodcastNetwork
Twitter: https://twitter.com/tfoxlaw
Instagram: https://www.instagram.com/voiceofcompliance/
Website: https://compliancepodcastnetwork.net/

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Corruption, Crime and Compliance

Deep Dive into The Trafigura FCPA Settlement

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions like Vitol, Sergeant Marine, Glencore, Freepoint, and Gunvor.

DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of 19 individuals, including six government officials, eight corrupt intermediaries, and five trading companies.

Trafigura Beheer B.V. (“Trafigura”), based in Switzerland, plead guilty and agreed to pay $126 million as part of a plea agreement to resolve FCPA violations in Brazil. Trafigura pleaded guilty to conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay a fine of over $80 million and forfeiture of $46 million. DOJ agreed to credit up to $26 million of the fine against the amounts Trafigura pays to resolve an ongoing Brazil investigation.

  • Trafigura, a global commodity trading company, pleaded guilty and agreed to pay $126 million to resolve FCPA violations in Brazil, involving a corrupt scheme to pay bribes to Brazilian officials to secure business with Petrobras.
  • DOJ cited Trafigura’s cooperation and acceptance of responsibility, including providing timely updates, facilitating employee interviews, and producing relevant documents, but criticized their failure to preserve and produce certain evidence in a timely manner.
  • Trafigura’s bribery scheme involved paying bribes to Petrobras officials from 2003 to 2014 to obtain and retain business, with payments ranging from 5 to 20 cents per barrel for oil transactions.
  • The bribery payments were facilitated through offshore bank accounts, U.S. banks, and coded language in emails, with Trafigura entities earning approximately $51 million in profits from the scheme.
  • DOJ’s successful sweep of the commodities trading industry resulted in six corporate resolutions and 20 individual convictions, totaling over $1.7 billion in penalties, emphasizing the importance of robust compliance and surveillance strategies.
  • Trafigura’s lack of compliance oversight and failure to maintain proper third-party due diligence or risk management programs allowed the bribery scheme to operate with impunity, highlighting the need for enhanced controls and monitoring in high-risk industries.
  • Despite the challenges faced during the investigation, Trafigura’s guilty plea and cooperation with DOJ demonstrate a commitment to addressing corruption and compliance issues in the global commodity trading sector.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Career Can D0

Boost Your Career with Travel with Cindy Peck

What if you could transform your life and career through the power of travel?

Join Mary Ann Faremouth on this episode of Career Can Do as she sits down with Cindy Peck, the mastermind behind Traveling Texans.

Cindy shares how traveling with a group can lead to new friendships, exposure to different cultures, and personal growth. With over 15 years of experience as a travel agent, Cindy has organized unforgettable trips that have left a lasting impact on the lives of many.

Discover the benefits of group travel, the importance of camaraderie in healthy aging, and how exploring the world can enhance your creativity and productivity in the workplace.

Traveling in a group offers numerous benefits, such as making new friends and experiencing new cultures. Cindy Peck, the founder of Traveling Texans, emphasizes the importance of camaraderie and new friendships as part of healthy aging. She states, “The group environment and making new friends are part of healthy aging.” Traveling with a group also provides safety, convenience, and competitive pricing, so you can explore the world and build lasting connections with like-minded individuals.

Travel allows for networking opportunities and potential professional connections you might not have otherwise. “You never know what’s going to come from taking a trip,” Mary Ann says, and she shares her own story of unexpected networking and job opportunities while on a cruise. One job candidate even impressed a potential employer by bonding over a shared love of Paris. At Traveling Texans, Cindy makes sure to welcome people of all ages from around the world, expanding that potential network even more.

Traveling in a group not only enriches your life with new experiences but also contributes to personal growth and well-being. Mary Ann reflects on how her trip with Traveling Texans inspired creativity, relaxation, and a sense of rejuvenation. She notes, “I came back from this trip so inspired, so rested, and so much more creative.” By stepping out of your comfort zone, exploring new destinations, and forming meaningful connections, you can enhance your overall well-being and cultivate personal growth.

Resources:

Cindy Peck on LinkedIn | Traveling Texans Instagram | Traveling Texans Meetup Page

Faremouth.com

Categories
Daily Compliance News

Daily Compliance News: April 15, 2024 – The 1st Criminal Trial Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • The US wants to beef up CFIUS. (WSJ)
  • Nigeria recovers $27MM in a corruption probe. (Barron’s)
  • Venezuela arrests more PdVSA execs. (Bloomberg)
  • Silence and omission are not securities fraud. (Reuters)

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

Categories
Compliance Tip of the Day

Compliance Tip of the Day: Impact of The Monaco Memo On Investigations

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we consider what additional pressure the Monaco Memo put on companies to get their investigations done quickly and to get it done right.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

Categories
All Things Investigations

All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, I joined by Mike DeBernardis to mine compliance lessons from the recently announced Gunvor and Trafigura FCPA enforcement actions.

Mike DeBernardis is a seasoned professional with a comprehensive understanding of FCPA enforcement actions and compliance matters, a perspective deeply informed by his numerous client advisory roles on self-disclosure decisions related to FCPA violations and his regular participation in industry discussions.

DeBernardis believes that FCPA enforcement actions are increasingly considering past misconduct as a determinant in assigning penalties and discounts. He underscores the necessity for companies to be proactive and innovative in their remediation efforts rather than simply adhering to minimal compliance standards. He also notes a decrease in the reliance on external monitors in FCPA resolutions, potentially due to businesses taking more initiative in improving their compliance programs and directly reporting to the DOJ.

In DeBernardis’ view, the Department of Justice’s approach to FCPA enforcement is dynamic and adaptive, with companies helping shape best practices through their communication with outside counsel and the DOJ itself.

Key Highlights:

  • Impact of Self-Disclosure on FCPA Penalties
  • DOJ’s Quantifiable Self-Disclosure Benefits in FCPA
  • Cross-Regional Executives in Trafigura Bribery Scheme
  • Innovative Risk Mitigation Strategies in FCPA
  • Rewarding Compliance Efforts in Energy Trading

Resources:

Hughes Hubbard & Reed website

Mike DeBernardis