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Hard Cases Make Bad Law – and more Layers of Compliance

The old legal maxim, “Hard Cases Make Bad Law,” has wide application. It reflects the difficulty of legislating in response to unusual or extreme circumstances. Often the result is a law that doesn’t serve well in general application, or it might come with unintended consequences. This is especially relevant now,  in the context of the

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Sanctions and PEP – Expect More and Stricter Implementation

In financial services, active compliance is more important than ever. The war in Ukraine, and the Gaza crisis, means that fallout from international relations reaches deep into the commercial world. Heightened geopolitical turmoil necessitates an even more robust approach to regulatory compliance. These must transcend standard procedures and look at all elements of KYC with

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Managing the Multiple Layers of Compliance – Efficiently

Across the world, the burden of regulatory compliance is not just growing – it’s accelerating rapidly. Financial institutions face a labyrinth of regulations that demand meticulous attention to detail and an in-depth understanding of international financial laws. Compliance tasks range from adhering to efficient and effective KYC routines and intelligent transaction monitoring, to navigating the

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Embracing the Complexity of Global Compliance

For financial institutions, compliance is not just a process. Like the sea, it’s continuously moving and changing, and it requires vigilance to stay in tune with  the latest laws, regulations and lists. Understanding this is crucial, especially when multiple jurisdictions are involved.  It’s necessary to navigate regulations accordingly, often when rules may change with little

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EU tightens up on AML

On 13th December 2023, the European Union  took a significant step forward in its fight against financial crime, especially anti-money laundering. Establishing the EU Anti-Money Laundering Authority (AMLA) is a testament to this commitment. The new body is designed to supervise and coordinate national authorities, enhancing their ability to detect and combat suspicious cross-border transactions.

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URGENT and EFFECTIVE AML is non-negotiable.

The 2023 Basel AML Index has brought to light an alarming escalation in global money laundering and terrorist financing risks. This annual report, emphasizing the urgent need for effective compliance measures, describes a concerning trend: despite robust frameworks, the effectiveness of systems for anti-money laundering (AML) and counter-terrorism funding (CFT) is in decline. As the

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The Shifting Sands of Financial Risk: Balancing Perception and Reality

In financial services, risk perception is often as significant as the risk itself. A recent report(1) in  The Business Times of Singapore reveals growing concerns among Singaporean financial institutions about money laundering risks. This comes in the wake of a major scandal in August 2023, where ten individuals were arrested for a money-laundering scheme involving

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Proactive Support: how tech supports vulnerable gamblers

In recent years, the gambling industry has made important strides in addressing problem gambling. Increasingly, the emphasis is on support for those at risk, rather than punitive measures. This shift reflects a growing recognition of the importance of responsible gambling practices and the need to protect vulnerable individuals. Some organisations have acted slowly but the

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How efficient is your risk-management? And is it effective?

The ideal payment system is frictionless, seamless and instantaneous – and free from the risks of financial crime. There’s the catch. As the financial world continues to get more complex and inter-reliant, the holy grail of simplicity and full regulatory compliance becomes seemingly more elusive. And while digital banking continues to grow more robust, systems

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No more excuses: compliance doesn’t need to slow down remittance services

Do you remember paying for things by paper check (that’s a ‘cheque’ if you’re reading this in the UK)? On the receiving end, remember the three-day wait, or more, while funds cleared? Thankfully those days are gone. On a personal level many people can access faster payment services that enable real time and near instantaneous

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Beating financial crime requires agility and foresight

Forget keeping up with the criminals. The financial services industry needs to get ahead of them. But there’s an inherent challenge. Financial criminal behavior is by its nature active and creative. Meanwhile the established ways of countering fraud, money laundering or terrorism funding tend to be re-active and less dynamic. Traditional anti-crime methods are failing

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Is you Compliance Policy a priority?

And are your policy and compliance handbook still up to date?

There was low-key but significant move in Colombo, Sri Lanka, recently. Reported on 6 October in Sri Lanka’s online Daily News*, the country’s Securities and Exchange Commission (SEC) and the Colombo Stock Exchange (CSE) met with businesses and compliance officers from market intermediaries to emphasise the importance of the compliance officer role.

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Problem gambling – nip it in the bud with digital

The growth of sports betting in the US, since 2018 and especially since the end of the pandemic, has accelerated exponentially. There are serious consequences for public health across the nation.

Sports betting is now lawful in 37 States plus DC. With this liberalization has come an increase in gambling addiction. It should not have been a surprise and for many observers it was expected. Europe and Asia have shown what happens when gambling is inadequately regulated, especially when it’s online.

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Streamlined early AML and Sanctions Checks are no longer a luxury

In the financial services sector, political and security constraints seem to grow ever more complex. At the same time, more and more business is conducted digitally. Fraud and unintended breaches of compliance are ever-present hazards. The interaction between these forces affects more of us, and does so more forcefully, than ever before.

Sanctions lists are updated frequently, and criminals leverage digital technology with skill. Anti-money laundering features prominently in compliance. In this world, it’s essential that the mechanisms in place to make appropriate checks are robust and responsive.

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Ban gambling or let the market run free?

For many, gambling is the harmless purchase of an occasional lottery ticket. And the majority of gamblers exercise good self-control, keeping even regular betting to a modest discretionary spend.

For others the picture is different. Those who are pre-disposed to addictive behaviours are easily drawn into gambling, sometimes with tragic consequences. Social harm caused by gambling can be extensive, and it’s estimated that, worldwide, addiction rates1 vary by country between 1.2% and 6.0% of the population.

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Legacy systems: tether or springboard?

Compliance costs money – something well understood in the financial services sector, including niche areas such as Gambling, and Travel Money and Remittance providers. But making compliance cost-effective can seem elusive.

As geopolitical tensions multiply, and as criminal activity expands in the digital environment, legislation and regulations multiply. The burden on individual businesses intensifies.

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Sports Betting – state legislators get more than they bargained for

The post 2018 relaxation of sports betting laws in the US has growing consequences, especially since the end of the pandemic. Not all of them are good.

Sports betting is currently lawful and under way in 34 states plus DC, and lawful and soon to be active in 4 more. State governments have sought and welcomed the extra revenue they’ll receive. For the same reason, many sports teams and their sports’ governing bodies have generally welcomed the move too.

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Responsible Gambling and Behavioral Monitoring

Interviewed recently for SBC Americas1 (a gambling industry news service covering the Americas), Odds on Compliance’s John Wellendorf set out structured advice for internet gambling operators.

His commentary reflects the reality of gambling regulation – that many US states have moved from a top-down model of imposing rules (which may still apply but have proved difficult to police) to requiring gambling platforms to demonstrate the use of effective internal responsible gaming management.

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Why accurate whole-person profiles are the key to fighting financial crime

In a recent article1 in Regulation Asia, Clare Rowley of GLEIF (the Global Legal Entity Identifier Foundation), sets out how comprehensive identification of legal entities and their behaviours is the key to fighting modern and future financial crime.

In fact, GLIEF’s very purpose is to provide “open, standardized and high-quality legal entity reference data. By doing so, GLEIF enables people and businesses to make smarter, less costly and more reliable decisions about who to do business with”.

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A better way to monitor betting to safeguard institutions, individuals and families

Individual rights are important. None more so than in how to spend our own money.

But simple freedoms are not always as simple as they look. Take gambling. There are few genuinely successful gamblers. And the unsuccessful majority includes a significant number who are addicted to the deceptive hope of that one big win.

Gambling addiction comes with personal financial stress and, crucially, real collateral damage to the families of addicts. Personal and social harm is destructive and extensive.

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How digital can make Hawala payments more secure.

Financial services such as money remittance face a simple challenge: how to get money from A to B safely, securely and especially, without abuse of the system by criminals.

A sensitive example is Hawala – an informal money transfer system that originated in India and is now also used widely in the Horn of Africa, and across the Middle East and North Africa. Dominant features are its emphasis on personal trust, and that it operates at low cost outside the “conventional” banking system.

How digital can make Hawala payments more secure. Read More »

6.92 billion potential gamblers, all with online access

For millennia the number of gambling addicts has been largely self-regulating, usually by a tragic journey to bankruptcy or worse.

Not so today. According to Statista, there are approximately 6.92 billion smartphone users in the world today – 85.88% of the world’s population. Gambling is no longer an activity tied to a location. We can bet nearly everywhere, from anywhere with a phone signal. Every smartphone enables easy financial transactions. They are the innocent tool by which a gambler may become an addict.

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Why real Anti-Money Laundering Protection is much more than an IT add-on

Getting ahead of the criminals has long been the holy grail of law enforcement. Anti-Money Laundering (AML) regulation is a perfect example, but it’s also an area where governments struggle to keep up.

Money laundering is a rapidly growing challenge worldwide: it’s estimated that it accounts for up to 5% of global GDP1. Such a threat means that AML processes need to be fully integrated into business operations – for peace of mind as well as financial protection.

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