Categories
Regulatory Ramblings

Regulatory Ramblings: Episode 48 – Defeating Money Laundering with Rational Thinking, Not Compliance Red-Flags with Mariola Marzouk (Vortex Risk Ltd.)

Dr. Mariola Marzoukis isan anti-money laundering (AML) professional with extensive experience in regulatory software and consulting across the public and private sectors. Her career has involved working with global banks on how to use technologies to address regulatory compliance demands.

In 2023, after completing her doctorate in criminal justice focused on trade-based money laundering (TBML) and technology, she co-founded Vortex Risk Ltd. with her colleague Dr Nicholas Gilmour (himself a guest on episode #18 of Regulatory Ramblings). The firm provides insights into money laundering practices to individuals and organizations worldwide. Vortex Risk’s approach empowers clients by offering perspectives akin to rational-thinking criminals operating discreetly to evade regulatory suspicion.

Over the course of her career, Mariola has held strategic product management positions at internationally recognized companies such as British Aerospace and Engineering (BAE) Applied Intelligence, EY, NICE Actimize, and Napier AI.

She specializes in financial crime prevention and has demonstrated expertise in detecting money laundering schemes using advanced technologies. Over time, her focus extended to the ever-growing specter of TBML, and her research in this area has garnered recognition within the industry. Mariola’s pilot study on Brexit’s impact on TBML has been published in the Journal of Money Laundering Control, featured on GTR News, and cited by the Institute of Export and International Trade UK.

In this episode of Regulatory Ramblings, she chats with host Ajay Shamdasani, describing her path from Poland to the UK, first as a student and now as a much sought-after financial crime professional in London.

The conversation underscores Mariola’s philosophy: defeating money laundering requires rational thinking and not merely compliance red flags. She eschews the notion of compliance as an exercise in perfunctory box-ticking and form-filing – a perennial lament in the profession.

She shares that her approach towards AML more generally is to precisely deploy RegTech to aid regulated entities in detecting criminality. While acknowledging that data analytics and artificial intelligence (AI) are essential tools in the battle against financial crime, she stresses that technology is not a panacea and works best when used in tandem with the skills, temperament, wisdom, and judgment that experienced professional researchers and investigators have developed over time. AI is no substitute for analysis by a human and good old common sense.

Mariola admits that while she does not have a background in science, technology, engineering, or math (STEM), her experience as a product manager and corporate strategist has afforded her insight into what customers need from technical solutions and a sense of discernment about when to apply which technologies, if at all. While not a techie per se, she has developed an understanding of technological development and how and when it should be deployed to solve specific problems. Ultimately, tools should meet the objectives of problem-solving, she says.

She recounts the various learning curves she experienced from the business side while coping with the more technical aspects of roles throughout her career.

The discussion concludes with Mariola stating her views on the prevailing hypocrisy in AML and sanctions enforcement. The financial world is all too often regulated from Washington, New York, London, and Brussels. Yet, while the US and UK are some of the most aggressive jurisdictions regarding financial crime enforcement actions, their regulatory apparatus is often used to further their geopolitical goals. It is a view outside of the West that Mariola says is not without merit.

Podcast Discussion

3:09 Mariola Marzouk’s Journey into Financial Crime

9:58 Combating Trade-Based Money Laundering: A Personal Pursuit of Restorative Justice

15:25 Disrupting the Norm: Money Laundering and Regulatory Realities

26:43 Unveiling Trade-Based Money Laundering: Beyond Trade Finance Myths

35:03 Technology in Regulatory Compliance: Unfulfilled Promises and Hidden Realities

41:08 The Disconnect and Challenges in Developing Effective RegTech Solutions

50:20 Challenges of Automation and Critical Thinking in Financial Crime Compliance

1:02:52 Assessing the Effectiveness of Sanctions Amidst Strategic Adaptations

1:06:34 Bridging Divides through Education

1:12:57 Gender Dynamics and the Future of Anti-Money Laundering

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Website: https://www.hkufintech.com/regulatoryramblings 

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Categories
Daily Compliance News

Daily Compliance News: December 5, 2023 – The Money – Laundering in Singapore 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 in 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.

Stories we are following in today’s edition:

  • Massive money-laundering case in Singapore (Bloomberg)
  • What employers expect employees to know about OpenAI. (BBC)
  • DeSantis claims Disney BOD had a COI. (Reuters)
  • The top Chinese anti-corruption cop will watch for extravagant spending. (South China Morning Post)
Categories
Daily Compliance News

January 20, 2023 – The More SCt Corruption 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.

Stories we are following in today’s edition of Daily Compliance News:

  • Supreme Court fails to ID leaker. (NYT)
  • Bitzlato was charged with money laundering. (WSJ)
  • Former Fox execs paid bribes, witness testifies at trial. (Reuters)
  • Elon Musk tweets take center stage in ‘funding secured’ trial. (TheVerge)
Categories
Innovation in Compliance

Passionate About AML with Simon Winchester

 

Simon Winchester is the Vice President of Advanced Technologies at Jumio Corporation. His responsibilities entail building the go-to-market strategies for newly acquired technologies within Jumio and then driving the adoption on a global scale. One of the company’s most recent additions is its AML (anti-money laundering) solutions. Tom Fox welcomes him to this week’s show to talk about current world events and the company’s AML solution. 

 

 

Money Laundering in 2022

Tom asks Simon if money laundering schemes have become more ubiquitous since the Russian invasion of Ukraine. Simon replies that the recent events certainly had an impact. He says that money laundering is “criminals taking illicitly-gained funds and then turning them into legitimate cash or assets which are ideally free of suspicion.” At the core of this criminal process are three themes: placement, layering, and integration. Due to the digital environment we live in today, more people from all demographics are comfortable with digital banking, and criminals now find it easier to launder money, which makes it more difficult to detect. Fortunately, Jumio works hard to provide AML solutions and offer more effective compliance programs. 

 

Key AML Regulations

Tom asks Simon what are some of the key AML regulations that Jumio advises clients on. It mostly depends on where your organization is located in the world, as local enforcement bodies drive AML regulations, Simon responds. These regulations will take a cue from international standards set by the Financial Action Task Force, which functions as a “global AML watchdog”. In the UK, the EU AML directives shape policy and provide guidance. Recently, they brought a new directive into effect which “increased the frequency of regulatory updates to the KYC and AML legislation, and brought a strict obligation to industries that were not previously subjected to severe AML protocol,” Simon tells Tom. 

 

Playing Catch-Up With Money Launderers

Tom asks Simon what Jumio sees as the key components of a successful AML program. Ideally, a company providing AML solutions should have a well-defined plan, Simon says. However, that is not feasible given the current climate. The components of a successful AML program, Simon says, include three steps: 

  • A dedicated compliance officer who is tasked with creating, monitoring and reviewing the compliance program, and staff training. 
  • A written risk-based compliance program with comprehensive AML policies and procedures that are documented. This approach identifies and protects your business from financial crime and includes having the technology in place to support that framework. 
  • An appropriate customer due diligence process, which means vetting your clients to avoid financial crimes. 

 

The Role of a CCO in AML Solutions

Simon believes that “Chief Compliance Officers are the catalyst for the growth and innovation”. He acknowledges how CCOs often get the raw end of the deal and their role in the organization must be scrutinized and changed. With the right AML technologies, compliance team, and effective AML program, a CCO and their team can drive shareholder value through organizational growth. 

 

Resources

Simon Winchester | LinkedIn 

Jumio Corporate | Website | LinkedIn | Twitter 

 

Categories
Everything Compliance

Episode 99, the Nobody Wants a Truth Cocktail Edition


Welcome to the only roundtable podcast in compliance. In 2021, Everything Compliance was honored by W3 as a top talk show in podcasting. In this episode, we have the quartet of Jay Rosen, Jonathan Marks, Tom Fox and Matt Kelly. We conclude with our fan favorite Shout Outs and Rants.

1. Jay Rosen discusses the hunt for Russian oligarch goods and funds. Rosen shouts out to gaslighters Marjorie Taylor Green and Kevin McCarthy for denying they made comments when the audio was played to them.

2. Matt Kelly takes a deep dive into the Stericycle FCPA enforcement action.  Kelly gives a shout out to the Brooklyn Public Library for offering a free library cards to those from towns where the GOP has banned books.

3. Jonathan Marks looks explores the FirstEnergy corruption case and its continued fallout in Ohio. Marks rants about Comcast which marketed a product which does not exist.

4. Tom Fox looks a provocative piece by Dick Cassin which posits the DOJ has changed enforcement priorities to remediation as the key goal. Fox shouts out to shareholders of Credit Suisse who revolted against the Board when it tried to shield itself from liability over its recent financial failures.

 The members of the Everything Compliance are:
•       Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
•       Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu
•       Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
•       Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com
•       Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at jonathan.marks@bakertilly.com
The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.