Categories
Innovation in Compliance

Navigating an Increasingly Complex Sanctions Landscape: How to Prepare for What’s on the Horizon

Welcome to this special podcast series “In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape”. This series is sponsored by K2 Intelligence, LLC. This week I have visited with Adam Frey, Managing Director, and Eric Lorber, Vice President at K2 Intelligence Financial Integrity Network (FIN).

Over the week, we have reviewed the current sanctions landscape, discussed how to build a sanctions compliance program, walked listeners through what happens when you discover a sanctions breach or potential breach, considered new sanctions exposure. Today, Adam Frey and I conclude with Episode 5 by taking a look in that veiled land of the future by considering issues on the horizon and how to prepare for it.

Resources
For more information on K2 Intelligence FIN’s Sanctions Risk Advisory Services, click here.
For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Categories
Innovation in Compliance

Navigating an Increasingly Complex Sanctions Landscape: New Exposures for Corporations and Shipping

Welcome to the podcast series: In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with  Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN.

Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 4, I am joined by Eric Lorber regarding new sanctions risk exposures for commercial corporations and in the shipping space.

Join us tomorrow for our concluding Episode 5 with Adam Frey as we peer down the road and consider some issues on the horizon for sanctions compliance.
Resources
For more information on K2 Intelligence FIN’s Sanctions Risk Advisory Services, click here.
For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Categories
Innovation in Compliance

Navigating an Increasingly Complex Sanctions Landscape: What Happens if You Have a Sanctions Violation

Welcome to the podcast series: In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with  Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN.

Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 3, I am joined by Eric Lorber On what to do if you have a sanctions violation or think you may have violated a sanctions program.

Frey concluded by stating, “these are the types of sort proactive steps that I think OFAC and the regulatory authorities would really like to see. It is signaling is we are taking this seriously. It’s very much a sort of a signal that we are on your side enforcement agencies and regulatory authorities.”
Join us tomorrow where I am joined again by Eric Lorber to consider new sanction risk exposures for commercial corporations and in the shipping space.
Resources
For more information on K2 Intelligence FIN’s Sanctions Risk Advisory Services, click here.
For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Categories
Innovation in Compliance

Navigating an Increasingly Complex Sanctions Landscape: Building an Effective Sanctions Compliance Program

Welcome to the podcast series: In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with  Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN.

Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 2, I am joined by Adam Frey to learn about how to build an effective sanctions compliance program.

We conclude with a few thoughts on the constant pressure for cost-cutting in the compliance function, which has been made more acute during the time of Covid-19. Frey noted that it “ is a consistent pressure. But I think it’s important to emphasize organizations really have to resist the urge to, to cut costs.” The reason is the cost of a compliance failure is so high and the regulators have said that all businesses must remain ever vigilant.  The idea of cutting corners now in an attempt to reduce costs could really end up adding costs down the line in terms of fines and penalties down the road.
Please join us tomorrow where Eric Lorber returns to discuss the actions you should take if you have sanctions violation or even a potential. While it depends somewhat on the size of the organization.
Resources
For more information on K2 Intelligence FIN’s Sanctions Risk Advisory Services, click here.
For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Categories
Innovation in Compliance

Navigating an Increasingly Complex Sanctions Landscape: The Current Landscape


Welcome to this special podcast series; In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with  Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN.
Frey is a key member of the firm’s independent consultant team, at the direction of federal, state, and/or international regulators, he works to monitor and assess global financial institutions’ compliance with AML and OFAC enforcement actions and related consent orders. Adam helps lead K2 Intelligence FIN’s reviews of the institutions’ BSA/AML and sanctions compliance programs, policies, and procedures. Lorber advises global financial institutions on issues related to sanctions and anti-money laundering/combating the financing of terrorism compliance. Prior to re-joining FIN, Eric was a senior advisor to the Under Secretary for Terrorism and Financial Intelligence at the United States Department of the Treasury, where he provided strategic guidance on U.S. sanctions and AML/CFT policies. Earlier in his career, he was an attorney at Gibson, Dunn & Crutcher, where he advised clients in the areas of international trade regulation, compliance, and anti-corruption. He is also the senior director of the Center of Economic and Financial Power at the Foundation for Defense of Democracies.
Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 1, I am joined by Eric Lorber to review the current sanctions landscape.
The bottom line is that sanctions are here to stay and every business needs to understand their impact to your company.
Please join us tomorrow where we discuss building a sanctions compliance program with Adam Frey.
Resources
For more information on K2 Intelligence FIN’s Sanctions Risk Advisory Services, click here.
For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Categories
Compliance and Coronavirus

Sepideh Rowland on the Impact of PPP on Financial Institution Compliance


Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I am joined by Sepideh Rowland, Vice President at K2 Intelligence FIN and head of managed services. She has over 20 years of regulatory compliance experience, including leadership positions at money services businesses, large financial institutions, and community banks. She is also Co-Chair of the U.S. Capital Chapter Advisory Board for ACAMS; as Co-Chair of the Advisory Board for the ABA/ABA Financial Crimes Enforcement Conference; and as an Advisory Board Member (former Chair) for the American Bankers Association Certified AML and Fraud Professional certification program.
In this episode, we consider the impact of the Payroll Protection Program on a bank’s Financial Crime Compliance Program; how has COVID-19 and PPP has impacted money laundering and fraud typologies; and conclude with how should banks think about their staffing models and resources.

Categories
Compliance and Coronavirus

Gabe Hidalgo on Lessons for Financial Institutions from the Coronavirus Health Crisis

Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I am joined by Gabe Hidalgo is a managing director at K2 Intelligence FIN. He has 20 years of legal, regulatory compliance, and AML experience working with wholesale and retail banks, FinTech companies, broker/dealers, and money services business entities. Hidalgo is a recognized subject-matter expert in the cryptocurrency and digital assets market. We discuss what Hidalgo sees as the top issues COVID-19 brought to light for financial entities, what should financial entities look out for as they begin to reopen and some core lessons learned that compliance programs can carry forward.

Categories
Innovation in Compliance

Defining and Building Effective Compliance Programs – What’s on the Horizon?


In this five-part podcast series, sponsored by K2 Intelligence FIN, we have considered defining and building effective compliance programs. I have been joined in this series by Michelle Goodsir, a Managing Director at K2 Intelligence, and Gail Fuller, Financial Integrity Network (FIN) Vice President. Michelle has 25 years of financial crime compliance experience which includes fraud risk management, anti-bribery and corruption, corporate security and investigations, sanctions, and Anti-Money Laundering (AML) program experience working within the financial services industry and the US government. Gail focuses on developing, refining, and implementing FIN’s quantitative and qualitative risk rating tools. She leads engagements focused on helping FIN’s jurisdictional and private sector clients understand their exposure to financial crime risk and develop and implement strategies to mitigate their risks.
Over this series we have considered key challenges in compliance, why compliance needs a seat at the table, how to do compliance on a budget; training and culture and what is on the horizon. In our conclusion, Part 5, I visit with Gail Fuller as we look into that veiled land of the future and view what’s on the horizon for compliance. Highlights include:

  • What are regulators looking for when it comes to compliance? Regulators are looking for professionals to be proactive and creative problems solvers. 
  • If compliance was an area that was previously not sufficiently funded, what are three things people need to do now if things are cut even further? Reinforce your commitment to compliance; rethink geographic distribution of your compliance team; and think through technology investments.
  • Thinking about this whole series, we talked about a lot of tips… what are the areas you’d suggest our listeners focus on as they look to rebuild or enhance their programs? Be sure to communication your compliance priorities clearly, leverage personnel to more fully operationalize compliance and then harness and pursue technologies.

Resources
K2 Intelligence financial crimes risk & compliance page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance 
K2 Intelligence AML page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-money-laundering-compliance
K2 Intelligence Anti-corruption page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-corruption
K2 Intelligence DOLFIN: https://www.finintegrity.com/dolfin.html

Categories
Innovation in Compliance

Defining and Building Effective Compliance Programs – Compliance on a budget: Solutions for entities of all sizes

In this five-part podcast series, sponsored by K2 Intelligence FIN, we consider defining and building effective compliance programs. I am joined in this series by Michelle Goodsir, a Managing Director at K2 Intelligence, and Gail Fuller, Financial Integrity Network (FIN) Vice President. Michelle has 25 years of financial crime compliance experience which includes fraud risk management, anti-bribery and corruption, corporate security and investigations, sanctions, and Anti-Money Laundering (AML) program experience working within the financial services industry and the US government. Gail focuses on developing, refining, and implementing FIN’s quantitative and qualitative risk rating tools. She leads engagements focused on helping FIN’s jurisdictional and private sector clients understand their exposure to financial crime risk and develop and implement strategies to mitigate their risks.

Over this series we are considering key challenges in compliance, why compliance needs a seat at the table, how to do compliance on a budget; training and culture and what is on the horizon. In Part 4, I visit with Gail Fuller on how to facilitate ongoing compliance training, communications and re-emphasizing culture in an organization.

Some of the highlights include.

  • What are some of the key components to a successful training program? They include comprehensive, tailored; effective training which is built into the culture; it is continuous and employees are held accountable.
  • Especially given all that is going on in the world, how can organizations ensure they are giving employees the right blend of in-person and online training? Regulators are neutral on method but a blend is really ideal as people learn in different ways. You should design your training program to take advantage of each form of training’s benefits. Finally be sure to make it engaging.
  • Once training is complete, how can entities ensure their teams are able to report issues? A kley is to have two buckets- one which is inward facing (governance focused) and a second which is outward facing (interactions with regulators).

Resources
K2 Intelligence financial crimes risk & compliance page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance 
K2 Intelligence AML page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-money-laundering-compliance
K2 Intelligence Anti-corruption page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-corruption
K2 Intelligence DOLFIN: https://www.finintegrity.com/dolfin.html

Categories
Innovation in Compliance

Navigating CFIUS Risks with Business Intelligence: Episode 4-CFIUS, Cyber Risk and Access Control

Welcome to a  sponsored podcast series where I am exploring how to navigate risk from the Committee on Foreign Investment in the United States (CFIUS), sponsored by K2 Intelligence Financial Integrity Network (K2 Intelligence FIN). Over this five-part series I will visit with David Holley and Him Das the co-leads of CFIUS Advisory Practice at K2 Intelligence FIN. We will consider navigating the CFIUS process through using business intelligence to identify CFIUS threats and vulnerabilities, using a proactive approach to navigate the CFIUS process, compliance frameworks for risks under CFIUS and effective monitoring for CFIUS. Today, in Episode 4, I visit with David Holley on the CFIUS and cyber risk and access control.
Highlights include:

  • Is it just cyber security companies, or how does CFIUS weigh this risk?
  • What steps can investors take to mitigate this in the initial processes?
  • What does an ongoing compliance framework look like to help catalyze continued success?