FinCrime World Forum 2021 Agenda

Session times shown below in Greenwich Mean Time Zone (GMT).

Tuesday 22nd June

8:00 am
A Talk on the Wild Side - A conversation on the Wildlife-FinCrime nexus with John Scanlon

The potential link between the illegal wildlife trade and the spread of COVID-19 has focused attention once again on the trafficking and exploitation of wild animals, as well as plants. Exotic animals can often bring incredible prices in illicit markets, and according to the UN, wildlife crime has become a “significant and specialised” form of transnational crime in its own right.

Australian lawyer John Scanlon has been one of the leading global voices against this trade, and currently holds three major positions with campaigning organisations: CEO of the Elephant Protection Initiative (EPI) Foundation, Chair of the Global Alliance to End Wildlife Crime, and Chair of the UK Government's Illegal Wildlife Trade Challenge Fund. He has also served as the Secretary-General of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) for nearly a decade between 2010-2018.

There are few campaigners as intimately aware of the realities of the illegal wildlife trade, and in this session, John will share his experiences of the fight, as well as his perspectives on how to go about tackling this pernicious problem more effectively. Looking to a dedicated and coordinated global effort, tougher regulation and enforcement, he argues that the illegal wildlife trade is “not a poor man’s crime”, and that governments need to focus on following dirty money in exactly the same way as with other major forms of serious organised criminality.

Interview with John E Scanlon AO, Chair, Global Initiative to End Wildlife Crime

9:00 am
Complying with Diversity Building an inclusive FinCrime profession

Critics often complain that the FinCrime compliance profession is something of a closed-shop for white, middle-class men who have worked for decades in the financial services sector, and dominate the top tiers of senior management in the field. This kind of characterisation is not wholly fair, of course. Increasing amounts of women are developing sustainable and successful careers in the industry, as too are those coming from a Black, Asian or Minority Ethnic (BAME) background. But most in the industry will admit that there is still a distance to go.

The industry also continues to be siloed in other ways, with financial services compliance still seen by many in the field as a ‘career for life’ that requires little input from other professional perspectives. This preconception has been challenged over the last decade too, by an influx of staff from public sector backgrounds such as law enforcement and intelligence, and increasing numbers of technically savvy individuals who work with data and advanced platforms. The rise of fintech has also played a role, bringing a wider range of young, talented individuals who want to challenge the ‘group think’ of pre-existing FinCrime approaches into the field.

In this session, our panellists will discuss the practical value that a diversity of skills and experience can bring to the execution of compliance and risk management, and consider the challenges that come with building and sustaining diverse teams. The panel will also identify good practice from both within and beyond the sector, to help firms get the best out of their people, whatever their backgrounds.

10:30 am
Moving the Needle - Defining, measuring, and improving FinCrime effectiveness

Many key players in the FinCrime world have been seeking to define the term ‘effectiveness’. Following the lead of the global standard setters, the Financial Action Task Force (FATF), most regulators have sought to assess the issue through subjective evaluations of ‘how well’ businesses meet their compliance obligations. Recently, the US federal government’s Financial Crimes Enforcement Network (FinCEN) has sought to take a more measurable approach, suggesting that an ‘effective’ FinCrime programme delivers ‘useful’ Suspicious Activity Reports (SARs) – in other words, financial intelligence that materially helps law enforcement investigations.

But despite such attempts to take a granular and concrete approach, the meaning of the term ‘effectiveness’ is still ambiguous for stakeholders in both the public and private sectors and is often re-interpreted to mean measuring what is easy – especially outputs and efficiency – rather what matters – outcomes and impact. In this panel therefore, we bring together a number of leading FinCrime practitioners to scrutinise what the term effectiveness can – and more importantly should – mean in the for the stakeholders in the FinCrime world, and explore pragmatic and practical ways in which all stakeholders can help ‘move the needle’ in a positive direction

Host:
John Cusack, Chair, Global Coalition to Fight Financial Crime
Panellists:
Geraldine Lawlor, Global Lead Partner for Financial Crime, KPMG LLP
Dr Ronald Pol, Director and Principal, TeamFactors.com and AMLassurance.com
Gemma Rogers, Co-founder, FINTRAIL
Daniel Thelesklaf, Director, Finance Against Slavery and Trafficking, UN University – Centre for Policy Research
Vishal Marria, CEO, Quantexa
                                   
11:20 am
Cultural Capital Can we achieve a positive FinCrime ‘compliance culture’?

For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.

12:10 pm
The Last Lines of Defence Strengthening the professions’ fight against FinCrime

Most public attention on the private sector’s efforts against FinCrime is devoted to the role of financial institutions, and in particular, banks. This is quite logical, given the centrality of their roles as the gatekeepers of the financial system, and the parts they have unwittingly played in moving illicit funds around the global economy.

However, FinCrime does not touch the financial sector alone, and the vulnerability of professions such as lawyers and accountants to becoming the tools of financial criminality has become more apparent in recent years. Estate agents’ services have also been abused by criminals seeking to ‘integrate’ illicit funds into the legitimate economy – indeed, the role illicit cash has played in property price booms has been widely reported. At the same time, the professions are still relatively minor reporters of suspicious activities to the authorities. Despite the warning signs, it does not appear that the professions have yet taken the issue as seriously as they should.

In this panel, our experts examine how financial criminals have made use of a variety of professional services to protect and enjoy their illicit funds, and ask why, so far, many firms in those sectors have failed to take FinCrime seriously. The panel will also consider ways in which regulators can encourage a more proactive approach, and how the wider private sector community can bring the professions into the fold.

Host:

Matthew Redhead, Associate Fellow, RUSI.


Panellists:

Dr Anna Bradshaw, Partner, Peters & Peters Solicitors LLP.
Dr Katie Benson, Lecturer in Criminology, Lancaster University.                                                    

1:00 pm
Above the Law? The challenge of bringing financial criminals to justice

The social restrictions of the COVID-19 pandemic have been a major impediment to financial criminals, who rely on easy access to the financial system to move dirty money. Law enforcement agencies – seeking to make the best of a difficult situation – have been able to take advantage, seizing large amounts of illicit cash that would otherwise have been laundered through the system, or smuggled to high-risk jurisdictions.

Nonetheless, these recent successes - often highlighted in the media - should not detract from the underlying reality that all law enforcement agencies are struggling to reduce the scale and scope of FinCrime. According to most reliable global estimates, no more than 1-2% of illicit funds are ever retrieved by the authorities – an astonishingly low figure.

Our panel of experts will probe into the reasons behind this apparent failure to retrieve funds and bring financial criminals to justice, exploring systemic weaknesses and vulnerabilities that generate such poor operational outcomes. At the same time, the panel will also explore the potential of new initiatives, such as Unexplained Wealth Orders (UWOs), to rebalance the playing field, and consider new ways in which the private sector could support the authorities’ campaign against financial criminals.

Host:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Panellists:

Aidan Larkin, CEO, Asset Reality

Carmel King, Director, Insolvency and Asset Recovery, Grant Thornton UK LLP

Sarah Hargreaves, ACI, ACE, Director of Training - International, Exterro      

2:30 pm
United We Stand The potential for integrated FinCrime teams and controls

The problem of fragmentation affects the world of FinCrime in many ways. Within compliance and risk management functions, the past isolation of AML, fraud and sanctions teams has led to key risks falling between the institutional gaps – a problem exacerbated when the teams use different platforms and data streams. FinCrime measures as conventionally applied also have temporal as well as organisational gaps, with retrospective monitoring leading to delays in suspicious activity reporting, and slow KYC refresh cycles meaning that customer risk profiles remain woefully out of date.

Many businesses are thus now seeking ways to make their FinCrime frameworks more responsive to real-time demands. Some larger financial institutions have restructured their FinCrime ‘estates’ to bring previously separate teams together and deployed new technologies to create a more integrated approach: concepts such as ‘seamless AML’ and ‘perpetual KYC’ have now started moving from idea to reality.

In this panel, our experts will investigate the problems of fragmentation and delay in traditional FinCrime frameworks and explore the progress that innovators in the financial services sector have made so far in creating a more coherent response, especially with new technologies. They will also consider where such changes are leading, and whether it is realistic to expect we can make our own frameworks as agile and coherent as those of the financial criminals themselves.

3:20 pm
Beyond the Banking Bubble Leveraging technology lessons from other industries

In the last few years, financial services providers and Regulatory Technology (RegTech) firms have talked a great deal about the deployment of new data-driven technologies, usually with a focus on automation and supervised machine learning to core compliance tasks such as sanctions screening and transaction monitoring. However, in spite of the competitiveness between RegTechs, platforms have sometimes been less advanced than they might seem, given their need to pass tight regulatory validation requirements.

In contrast, other industries and sectors are finding ambitious ways in which to leverage new technologies with fewer constraints. In healthcare, for example, providers are increasingly using more advanced supervised and unsupervised machine learning models, allowing Artificial Intelligence (AI) to play greater roles in decision-making in diagnosis and prescription. If a ‘trust but verify’ approach can be applied to human health, there are questions to ask about why we cannot take the same stance when it comes to financial crime risk.

In this session, our panel of experts will therefore take us beyond the boundaries of the FinCrime world, to explore the ways in which new technologies are being applied to other industries and sectors; consider how their techniques might be translated into the fight against financial crime; and review the ways in which FinCrime regulators too could learn from their counterparts in other sectors.

4:10 pm
Pushing for the RegTech Revolution Removing the barriers to adoption in FinCrime

In a recent report, the City of London Corporation has argued that the financial services sector needs to leverage new regulatory technologies (RegTech) to meet their obligations and fight financial crime. The report follows a succession of other statements from leading regulators in the US, Europe and Asia-Pacific, all making similar points.

However, as the City of London also notes, the take up of RegTech – though comparatively better in the FinCrime space than other areas – is still limited overall. A lack of practical rather than rhetorical regulator support has been proposed as one cause for this, and there are likely to be other barriers too. Some of the most innovative RegTechs are relatively small or young firms that find it difficult to satisfy the risk requirements of large and mature financial institutions. Even when the solution on offer is a good fit, it can sometimes be impractical for either side to work together.

In this session, the panellists will provide a pragmatic view on the state of RegTech adoption in the industry and seek to get to the root causes of its currently slow pace, looking at regulatory, commercial as well as technological points of friction. The panel will also look at ways the current initiatives to support RegTech, such as regulatory sandboxes and ‘Tech Sprints’, might be enhanced and expanded in order to ensure the sector meets its full potential in the future.

Host:

Christopher Woolard CBE, Partner, EMEIA Financial Services Consulting & Chair, EY Global Regulatory Network, EY LLP

Panellists:

Dr Sian Lewin, Co-Founder and Head of Client Delivery, RegTech Associates

Francesca Hopwood Road, Head of RegTech & Advanced Analytics, FCA

8:15 am
FinCrime’s Pivotal Moment - A conversation with Burkhard Mühl, Head of the European Financial & Economic Crime Centre, Europol

The 2021 Serious and Organised Crime Threat Assessment (SOCTA) from Europol, the EU’s policing agency, made for sombre reading. According to the report, organised criminality in Europe is more complex and fluid than ever before, with different criminal gangs working together ‘as needed’, on the basis of mutual self-interest. Unlike the old-fashioned ‘Godfather’ model of organised criminality imagined in films and TV, modern master criminals are now as agile and collaborative as the entrepreneurs of the technology sector. Laundering the funds generated by these illicit criminal activities has become as equally sophisticated as the predicate crimes themselves, with professionalised networks, often operating through legitimate business structures, insulated from effective disruption by systemic corruption of individuals in the public sector, financial institutions and professions. As a consequence, the management of illicit finance has become deeply rooted in societies and economies, with its scale and complexity probably significantly greater than previously thought.

In this interview, we explore these issues in depth with Burkhard Mühl, since December 2020 the Head of the newly created European Financial & Economic Crime Centre (EFECC) at Europol. Herr Mühl – a 35-year veteran of Austrian and European law enforcement – believes that serious and organised crime and illicit finance are now major challenges for the EU, and therefore need to be addressed not only with new vigour, but a more strategic approach that targets the ‘high value’ kingpins at the centres of the networks. He also contends that to put organised criminals and money launderers on the defensive, law enforcement agencies and their partners in the private sector will need to learn lessons from their opponents’ success – by becoming ‘masters of collaboration’ in their own right.

Interview with Burkhard Mühl, Head of European Financial & Economic Crime Centre, Europol        

9:00 am
Tackling the Dark Underbelly of the Illegal Wildlife Trade A presentation by Araluen Schunmann, Director, Pangolin Crisis Fund

Anti-financial crime practitioners know that the illicit trade in wildlife has become a major source of illicit funds in the global criminal economy. But what do practitioners know about how the criminals conduct their business? In comparison to illicit activities such as drugs and human trafficking, the modus operandi of illicit wildlife traders is much less well-known. There are good reasons for this, of course, given the relative immaturity of the international effort to tackle the problem. But even so, we are learning – slowly – about how the wildlife traffickers operate.

In this presentation, Araluen Schunmann, Director of the Pangolin Crisis Fund for the Wildlife Conservation Network (WCN), will explore how the trade works, providing insights into the international supply chain for wildlife, the demand and supply that drive the illegal market, and the important role that corruption plays in enabling the trade. She will also explore how law enforcement agencies and NGOs seek to investigate these crimes, while providing a frank assessment of the roadblocks they face. What good can a SAR do against a sophisticated international network, and what prospects are there for the investigation and prosecution of traffickers at the top of the criminal organisations, rather than lower-level operatives who facilitate the trade on a day-to-day basis? Providing a balanced view of where we are in the fight, the presentation will not only explore emerging strategies for tackling the trade, but also address what else will need to change for the international community to have a significant impact.

Presented by Araluen Schunmann, Director of the Pangolin Crisis Fund, ‎Wildlife Conservation Network

9:45 am
Fighting Kleptopia -A conversation with Tom Burgis, author of ‘Kleptopia: How Dirty Money is Conquering the World’.

Even a decade ago, the emergence of kleptocracy – a political system where leaders use their positions of power to enrich themselves – was seen by those living in ‘developed’ states as being a marginal risk that affected only poor or undemocratic societies. However, as we have learned since then, no society – however well-established – is immune from the lure of financial and political corruption.

One of the leading journalists chronicling the progress of kleptocracy across the world is Tom Burgis, an award-winning reporter and a long-standing member of the Financial Times’ investigations team. In his most recent book, Kleptopia, published in 2020, Burgis exposes how seemingly disparate events, such as a massacre on the Kazakh steppe or a stolen election in Zimbabwe, can be linked to a hidden web of connections that touches centres of power not only in Beijing and the Kremlin, but also the City of London and, ultimately, the White House.

In this session, Burgis will discuss the inner workings of this growing global network of kleptocratic elites, and the efforts of quiet heroes seeking to highlight this problem, such as the compliance officer-turned-whistleblower Nigel Wilkins, who features in the book. Burgis also will explore how half-hearted government and private sector initiatives have failed to challenge the problems of corruption and illicit finance so far, and consider more effective ways to take the fight to the kleptocrats, now.  

Interview with Tom Burgis, Investigations correspondent, Financial Times

10:30 am
From Siloes to Systemic Solutions: FinCrime Utilities - Long term solutions?

FinCrime professionals often argue that one of the major challenges they face is the fragmentation of the anti-FinCrime effort: not only between the public and private sectors, but between firms themselves. With each individual business seeking to identify high-risk clients and suspicious activities through their own resources alone, it can be relatively simple for sophisticated financial criminals to work around the system. One idea often discussed has been that of ‘utilities’: institutions pooling their resources and working together to undertake their FinCrime obligations jointly. The most common experiments so far have been with KYC utilities in Asia-Pacific, Africa and Europe. Separately, a group of five major banks in the Netherlands has also started building the world’s first Transaction Monitoring utility.

These kinds of projects - combining data or taking a systemic, network view - should in theory improve the industry’s ability to understand and tackle common risks. However, so far, this has not been fully demonstrated, and utilities have also generated substantial practical issues of implementation. Some of these have been unique to the specific requirements of the project at hand, whether KYC or monitoring, while others appear to be more common. Integrating the data from multiple diverse institutions has proved a technical headache for some in the KYC space already, and in a world where personal data privacy is increasingly privileged, data-pooling has faced major challenges from developments such as the EU’s General Data Protection Regulation (GDPR).  Surveying this complex landscape, the panel will assess the potential value that utilities can bring to different aspects of the fight against FinCrime, and the balance between risk and reward that might come with such ambitious collaborations.

Host:

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research    


Panellists:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Helène Erftemeijer, KYC Lead, ING

Che Sidanius, Global Head of Financial Crime and Industry Affairs, Refinitiv

Lora von Ploetz, Director/Head of Global Financial Crime Unit, Commerzbank AG                                  

11:20 am
The Key to FinCrime? Encryption, Privacy Enhancing Technologies and the data-sharing challenge

A common refrain amongst FinCrime professionals is that it would be easier to take on the criminals if they were more readily able to share sensitive information between organisations. Whereas criminals have no barriers to worry about in this regard, those tasked with detecting and disrupting them have to follow closely the requirements of data and privacy law, which have often proved prohibitive.

For some time, the problem has been without a potential solution. However, over recent years, the development of advanced encryption techniques, often described as ‘Privacy Enhancing Technologies’ (PETs), have opened up new opportunities for smart data sharing. According to their proponents, PETs can help institutions combine and analyse sensitive data that remains can encrypted throughout – effectively ‘sharing’ without sharing.

The potential implications for financial intelligence partnerships are significant and have thus become a major topic of interest amongst FinCrime professionals. In this session, our experts will explore the promise of PETs: from the potential FinCrime ‘use cases’, the evidence of value and workability, to the practical challenges – from the technological to the regulatory – they might also bring.

Host:

Seán Doyle, Lead, Cybersecurity and Anti-Financial Crime, World Economic Forum

 
Panellists:

Rina Shainski, Co-founder and Chairwoman, Duality Technologies

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research

12:50 pm
FinCrime’s Wider Responsibility- Environmental, Social and Governance Reporting in FinCrime Compliance A presentation by Michael Rasmussen

In a world increasingly concerned with nurturing sustainability, businesses now take a greater interest in the wider impacts that they have on the environments and societies in which they operate. As part of this trend, Environmental, Social and Governance (ESG) reporting has become a common feature of how businesses seek to manage and explain their approach to these issues to regulators, investors, customers and employees.

Nonetheless, despite its recent spread, ESG reporting is often not fully understood, even in compliance tems. Although the issue of environmental impact is well-known, the full gamut of social concerns that need to be covered in ESG, from privacy, modern slavery, through to inclusion and diversity – are much less appreciated, as too is the role that governance needs to play in the management of financial crime risks such as fraud, bribery and corruption. To have an effective ESG program requires that financial crime compliance teams be a critical part of the reporting strategy.

In this session, Michael Rasmussen, aka ‘The GRC Pundit’, will help participants think through the essentials of an effective ESG program, and will cover: challenges of definition and scope; the clarification of regulatory and stakeholder requirements; the role that financial crime compliance teams need to play; and strategy and processes of ESG reporting. Michael is an internationally recognised commentator and consultant on Governance, Risk and Compliance (GRC) – a term he himself coined – and has over three decades of experience in the field. A popular presenter from our March conference, we are delighted to welcome him back

Presented by Michael Rasmussen, GRC Analyst & Pundit, GRC 20/20 Research

2:00 pm
The Real Ingredients of Virtual Compliance ‘Baking-in’ FinCrime good practice from the start

For entrepreneurs in any space there is often a desire to do things ‘differently’. Indeed, that is a prime motivation: to deliver a new product to customers. It can be tempting to focus on getting this right, providing a high-quality customer experience, and stimulating growth, to the exclusion of other concerns. Although compliance, regulation and risk management do not get ignored, they can slip down the list of priorities.

This has undoubtedly been a common challenge in the Virtual Assets sector, where innovators focused on developing new types of asset, product or service have sometimes found themselves dealing with issues of financial crime compliance last - with dire commercial and sometimes legal consequences. In some recent cases, the spread of stronger global AML/CFT requirements for the industry has led firms who did not factor such matters in from the start to go out of business. In other cases, failures to meet regulatory requirements have led to fines and regulatory censure.

If the Virtual Assets sector is to continue its remarkable growth, therefore, entrepreneurs and firms in the sector will need to develop sustainable ways in which to approach core compliance and risk management requirements from the start. In this session, our panel of experts will consider the ways in which Virtual Assets innovators have addressed these issues so far – successfully and otherwise – and seek to glean learning points for how Virtual Assets firms can ‘bake-in’ good practice, and develop sustainable FinCrime frameworks as an ingredient of long-term success.

Host:

• David Rowe-Francis, Founder, Praxis Compliance Consultants

Panellists:

Araba Eshun, Head of Compliance & MLRO, UK, Gemini Europe Limited

Caitlin Barnett, Director of Regulations and Compliance, Chainalysis                                                

2:50 pm
Crypto 2.0 – New ways of performing old tricks? Exploring Crypto Typologies with Nick Furneaux

Any sufficiently new technology can seem like magic to the uninitiated, and it can become easy to assume that its abuse by criminals is equally magical and just as perplexing. It can also become a natural next step to assume that there is a particular type of ‘crime’ inherent to the new technology in question.

Rarely in recent years have new technologies been so quickly framed in this way as blockchain and cryptocurrencies. FinCrime discourse has quickly assumed that not only is cryptocurrency inherently riskier than fiat currency, but that there is a particular form of distinctive crime – ‘crypto crime’ – that is intimately linked to it.

But despite these presumptions, the truth about the criminal abuse of cryptocurrency is considerably more prosaic. ‘Crypto crimes’ are in fact just good, old-fashioned crimes, with a new ‘virtual’ twist, according to Nick Furneaux, Managing Director of CSITech and author of Investigating Cryptocurrencies. In this session, Nick will follow up his popular talk from our March conference with an exploration of the classic criminal typologies that get applied to cryptocurrencies and provide potential investors with a range of issues to consider when dealing safely in this evolving market.

Presented by Nick Furneaux, MD at CSITech and CTO at Asset Reality                                                  

3:50 pm
Off the Crypto Rollercoaster Are stable coins and centralised digital currencies 'safe' alternatives?

In the face of soaring market values for a variety of cryptocurrencies, public authorities and established financial institutions across the world have been forced to start considering the implications of these assets’ wider usage. Cryptocurrencies are no longer seen to be a ‘fringe’ interest, or of little relevance to the wider economy.

Nonetheless, concerns continue about the perceived risks of market failure and abuse that come with the assets. Organisations in the public and private sectors are both trying to clarify their approaches to the issue. Some are rejecting crypto outright, while others are choosing to ride the rollercoaster. But between the extremes, others have been seeking to develop crypto in a more ‘risk friendly’ way. Private stablecoins – cryptocurrencies linked to the value of more tangible assets – are one proposed solution – while fully digitalised versions of pre-existing fiat currencies are another.

In this panel, our experts will explore the growing diversity of virtual and digital currencies, the likely future trends, and the growing role that governments and ‘big technology’ firms are seeking to play in the space. They will also ask whether these alternatives can really have the same market appeal as pure ‘crypto’ - without the potential risks.

4:40 pm
Scanning the Virtual Horizon The next steps for global Virtual Asset regulation

In March 2021, the Financial Action Task Force (FATF), the international standard setter for FinCrime, issued new guidelines on a risk-based approach to Virtual Assets and Virtual Asset Service Providers. Coming less than two years after its first guidelines on the area, the document has sought to clarify uncertainties, fill gaps, and update the rules in light of the fast-growing scope of the sector. Overall, the new guidelines have pointed towards a more stringent approach than before, with a widened definition of Virtual Assets, and additional references to stable coins, Decentralised Finance (DeFi) and Non-Fungible Tokens (NFT). Some FATF members have already starting taking a tougher line on the question, and those that have not are likely to follow suit in the near future.

But is this the right approach for Virtual Assets, or even the only approach? Is it possible to continue to apply a framework designed for fiat currencies to the virtual space? Or will a bespoke approach be required? In this panel, our speakers will review the current ‘state of play’ in the regulation of Virtual Assets, the philosophy behind regulators’ policies, and assess where regulators might go next. The panel will explore whether other regulatory models or bespoke alternatives might be applied to better effect, and the potential scope for regulatory innovation.

5:30 pm
Scams: Fuelling the Crypto Fire A presentation by Scott Johnson, Chainanalysis

In its 2021 Crypto Crime Report, Chainanalysis, a leading blockchain analysis company, found that scams – ranging from Darknet market abuse, extortion, phishing to Ponzi schemes – continue to be the highest-grossing forms of cryptocurrency-based crime, bringing in around $2.7 billion to criminals. Last year, scam-type crimes – especially fake investment schemes – were also affecting more individuals than ever before, with the number of separate payments to scam addresses rising from just over 5 to 7.3 million – a potential rise in victim numbers of more than 48%. Scams have always been big business for serious organised criminality, and the expansion of cryptocurrency usage has provided new options not only to make money, but to launder it too.In this session, we will be hearing from Scott Johnston, Head of Public Sector Outreach (EMEA) at Chainanalysis, the company behind the report, who will provide a realistic and evidence-driven overview of where we are with crypto-linked scamming. Scott – a former UK police officer with 18 years’ experience investigating serious organised crime, money laundering and emerging crypto threats – will help participants understand what the headline figures mean in practice, learning about 2020’s most significant scam-related cases and the likely trends in the crypto crime ecosystem in 2021. Scott will also explore how we can start to take ‘the fuel off the fire’, using blockchain analysis as a way to profile and track down scammers and identify new leads.

Presented by Scott Johnston, Head of Public Sector Operations, EMEA, Chainalysis                                                  

Wednesday 23rd June

8:00 am
A Talk on the Wild Side - A conversation on the Wildlife-FinCrime nexus with John Scanlon

The potential link between the illegal wildlife trade and the spread of COVID-19 has focused attention once again on the trafficking and exploitation of wild animals, as well as plants. Exotic animals can often bring incredible prices in illicit markets, and according to the UN, wildlife crime has become a “significant and specialised” form of transnational crime in its own right.

Australian lawyer John Scanlon has been one of the leading global voices against this trade, and currently holds three major positions with campaigning organisations: CEO of the Elephant Protection Initiative (EPI) Foundation, Chair of the Global Alliance to End Wildlife Crime, and Chair of the UK Government's Illegal Wildlife Trade Challenge Fund. He has also served as the Secretary-General of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) for nearly a decade between 2010-2018.

There are few campaigners as intimately aware of the realities of the illegal wildlife trade, and in this session, John will share his experiences of the fight, as well as his perspectives on how to go about tackling this pernicious problem more effectively. Looking to a dedicated and coordinated global effort, tougher regulation and enforcement, he argues that the illegal wildlife trade is “not a poor man’s crime”, and that governments need to focus on following dirty money in exactly the same way as with other major forms of serious organised criminality.

Interview with John E Scanlon AO, Chair, Global Initiative to End Wildlife Crime

9:00 am
Complying with Diversity Building an inclusive FinCrime profession

Critics often complain that the FinCrime compliance profession is something of a closed-shop for white, middle-class men who have worked for decades in the financial services sector, and dominate the top tiers of senior management in the field. This kind of characterisation is not wholly fair, of course. Increasing amounts of women are developing sustainable and successful careers in the industry, as too are those coming from a Black, Asian or Minority Ethnic (BAME) background. But most in the industry will admit that there is still a distance to go.

The industry also continues to be siloed in other ways, with financial services compliance still seen by many in the field as a ‘career for life’ that requires little input from other professional perspectives. This preconception has been challenged over the last decade too, by an influx of staff from public sector backgrounds such as law enforcement and intelligence, and increasing numbers of technically savvy individuals who work with data and advanced platforms. The rise of fintech has also played a role, bringing a wider range of young, talented individuals who want to challenge the ‘group think’ of pre-existing FinCrime approaches into the field.

In this session, our panellists will discuss the practical value that a diversity of skills and experience can bring to the execution of compliance and risk management, and consider the challenges that come with building and sustaining diverse teams. The panel will also identify good practice from both within and beyond the sector, to help firms get the best out of their people, whatever their backgrounds.

10:30 am
Moving the Needle - Defining, measuring, and improving FinCrime effectiveness

Many key players in the FinCrime world have been seeking to define the term ‘effectiveness’. Following the lead of the global standard setters, the Financial Action Task Force (FATF), most regulators have sought to assess the issue through subjective evaluations of ‘how well’ businesses meet their compliance obligations. Recently, the US federal government’s Financial Crimes Enforcement Network (FinCEN) has sought to take a more measurable approach, suggesting that an ‘effective’ FinCrime programme delivers ‘useful’ Suspicious Activity Reports (SARs) – in other words, financial intelligence that materially helps law enforcement investigations.

But despite such attempts to take a granular and concrete approach, the meaning of the term ‘effectiveness’ is still ambiguous for stakeholders in both the public and private sectors and is often re-interpreted to mean measuring what is easy – especially outputs and efficiency – rather what matters – outcomes and impact. In this panel therefore, we bring together a number of leading FinCrime practitioners to scrutinise what the term effectiveness can – and more importantly should – mean in the for the stakeholders in the FinCrime world, and explore pragmatic and practical ways in which all stakeholders can help ‘move the needle’ in a positive direction

Host:
John Cusack, Chair, Global Coalition to Fight Financial Crime
Panellists:
Geraldine Lawlor, Global Lead Partner for Financial Crime, KPMG LLP
Dr Ronald Pol, Director and Principal, TeamFactors.com and AMLassurance.com
Gemma Rogers, Co-founder, FINTRAIL
Daniel Thelesklaf, Director, Finance Against Slavery and Trafficking, UN University – Centre for Policy Research
Vishal Marria, CEO, Quantexa
                                   
11:20 am
Cultural Capital Can we achieve a positive FinCrime ‘compliance culture’?

For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.

12:10 pm
The Last Lines of Defence Strengthening the professions’ fight against FinCrime

Most public attention on the private sector’s efforts against FinCrime is devoted to the role of financial institutions, and in particular, banks. This is quite logical, given the centrality of their roles as the gatekeepers of the financial system, and the parts they have unwittingly played in moving illicit funds around the global economy.

However, FinCrime does not touch the financial sector alone, and the vulnerability of professions such as lawyers and accountants to becoming the tools of financial criminality has become more apparent in recent years. Estate agents’ services have also been abused by criminals seeking to ‘integrate’ illicit funds into the legitimate economy – indeed, the role illicit cash has played in property price booms has been widely reported. At the same time, the professions are still relatively minor reporters of suspicious activities to the authorities. Despite the warning signs, it does not appear that the professions have yet taken the issue as seriously as they should.

In this panel, our experts examine how financial criminals have made use of a variety of professional services to protect and enjoy their illicit funds, and ask why, so far, many firms in those sectors have failed to take FinCrime seriously. The panel will also consider ways in which regulators can encourage a more proactive approach, and how the wider private sector community can bring the professions into the fold.

Host:

Matthew Redhead, Associate Fellow, RUSI.


Panellists:

Dr Anna Bradshaw, Partner, Peters & Peters Solicitors LLP.
Dr Katie Benson, Lecturer in Criminology, Lancaster University.                                                    

1:00 pm
Above the Law? The challenge of bringing financial criminals to justice

The social restrictions of the COVID-19 pandemic have been a major impediment to financial criminals, who rely on easy access to the financial system to move dirty money. Law enforcement agencies – seeking to make the best of a difficult situation – have been able to take advantage, seizing large amounts of illicit cash that would otherwise have been laundered through the system, or smuggled to high-risk jurisdictions.

Nonetheless, these recent successes - often highlighted in the media - should not detract from the underlying reality that all law enforcement agencies are struggling to reduce the scale and scope of FinCrime. According to most reliable global estimates, no more than 1-2% of illicit funds are ever retrieved by the authorities – an astonishingly low figure.

Our panel of experts will probe into the reasons behind this apparent failure to retrieve funds and bring financial criminals to justice, exploring systemic weaknesses and vulnerabilities that generate such poor operational outcomes. At the same time, the panel will also explore the potential of new initiatives, such as Unexplained Wealth Orders (UWOs), to rebalance the playing field, and consider new ways in which the private sector could support the authorities’ campaign against financial criminals.

Host:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Panellists:

Aidan Larkin, CEO, Asset Reality

Carmel King, Director, Insolvency and Asset Recovery, Grant Thornton UK LLP

Sarah Hargreaves, ACI, ACE, Director of Training - International, Exterro      

2:30 pm
United We Stand The potential for integrated FinCrime teams and controls

The problem of fragmentation affects the world of FinCrime in many ways. Within compliance and risk management functions, the past isolation of AML, fraud and sanctions teams has led to key risks falling between the institutional gaps – a problem exacerbated when the teams use different platforms and data streams. FinCrime measures as conventionally applied also have temporal as well as organisational gaps, with retrospective monitoring leading to delays in suspicious activity reporting, and slow KYC refresh cycles meaning that customer risk profiles remain woefully out of date.

Many businesses are thus now seeking ways to make their FinCrime frameworks more responsive to real-time demands. Some larger financial institutions have restructured their FinCrime ‘estates’ to bring previously separate teams together and deployed new technologies to create a more integrated approach: concepts such as ‘seamless AML’ and ‘perpetual KYC’ have now started moving from idea to reality.

In this panel, our experts will investigate the problems of fragmentation and delay in traditional FinCrime frameworks and explore the progress that innovators in the financial services sector have made so far in creating a more coherent response, especially with new technologies. They will also consider where such changes are leading, and whether it is realistic to expect we can make our own frameworks as agile and coherent as those of the financial criminals themselves.

3:20 pm
Beyond the Banking Bubble Leveraging technology lessons from other industries

In the last few years, financial services providers and Regulatory Technology (RegTech) firms have talked a great deal about the deployment of new data-driven technologies, usually with a focus on automation and supervised machine learning to core compliance tasks such as sanctions screening and transaction monitoring. However, in spite of the competitiveness between RegTechs, platforms have sometimes been less advanced than they might seem, given their need to pass tight regulatory validation requirements.

In contrast, other industries and sectors are finding ambitious ways in which to leverage new technologies with fewer constraints. In healthcare, for example, providers are increasingly using more advanced supervised and unsupervised machine learning models, allowing Artificial Intelligence (AI) to play greater roles in decision-making in diagnosis and prescription. If a ‘trust but verify’ approach can be applied to human health, there are questions to ask about why we cannot take the same stance when it comes to financial crime risk.

In this session, our panel of experts will therefore take us beyond the boundaries of the FinCrime world, to explore the ways in which new technologies are being applied to other industries and sectors; consider how their techniques might be translated into the fight against financial crime; and review the ways in which FinCrime regulators too could learn from their counterparts in other sectors.

4:10 pm
Pushing for the RegTech Revolution Removing the barriers to adoption in FinCrime

In a recent report, the City of London Corporation has argued that the financial services sector needs to leverage new regulatory technologies (RegTech) to meet their obligations and fight financial crime. The report follows a succession of other statements from leading regulators in the US, Europe and Asia-Pacific, all making similar points.

However, as the City of London also notes, the take up of RegTech – though comparatively better in the FinCrime space than other areas – is still limited overall. A lack of practical rather than rhetorical regulator support has been proposed as one cause for this, and there are likely to be other barriers too. Some of the most innovative RegTechs are relatively small or young firms that find it difficult to satisfy the risk requirements of large and mature financial institutions. Even when the solution on offer is a good fit, it can sometimes be impractical for either side to work together.

In this session, the panellists will provide a pragmatic view on the state of RegTech adoption in the industry and seek to get to the root causes of its currently slow pace, looking at regulatory, commercial as well as technological points of friction. The panel will also look at ways the current initiatives to support RegTech, such as regulatory sandboxes and ‘Tech Sprints’, might be enhanced and expanded in order to ensure the sector meets its full potential in the future.

Host:

Christopher Woolard CBE, Partner, EMEIA Financial Services Consulting & Chair, EY Global Regulatory Network, EY LLP

Panellists:

Dr Sian Lewin, Co-Founder and Head of Client Delivery, RegTech Associates

Francesca Hopwood Road, Head of RegTech & Advanced Analytics, FCA

8:15 am
FinCrime’s Pivotal Moment - A conversation with Burkhard Mühl, Head of the European Financial & Economic Crime Centre, Europol

The 2021 Serious and Organised Crime Threat Assessment (SOCTA) from Europol, the EU’s policing agency, made for sombre reading. According to the report, organised criminality in Europe is more complex and fluid than ever before, with different criminal gangs working together ‘as needed’, on the basis of mutual self-interest. Unlike the old-fashioned ‘Godfather’ model of organised criminality imagined in films and TV, modern master criminals are now as agile and collaborative as the entrepreneurs of the technology sector. Laundering the funds generated by these illicit criminal activities has become as equally sophisticated as the predicate crimes themselves, with professionalised networks, often operating through legitimate business structures, insulated from effective disruption by systemic corruption of individuals in the public sector, financial institutions and professions. As a consequence, the management of illicit finance has become deeply rooted in societies and economies, with its scale and complexity probably significantly greater than previously thought.

In this interview, we explore these issues in depth with Burkhard Mühl, since December 2020 the Head of the newly created European Financial & Economic Crime Centre (EFECC) at Europol. Herr Mühl – a 35-year veteran of Austrian and European law enforcement – believes that serious and organised crime and illicit finance are now major challenges for the EU, and therefore need to be addressed not only with new vigour, but a more strategic approach that targets the ‘high value’ kingpins at the centres of the networks. He also contends that to put organised criminals and money launderers on the defensive, law enforcement agencies and their partners in the private sector will need to learn lessons from their opponents’ success – by becoming ‘masters of collaboration’ in their own right.

Interview with Burkhard Mühl, Head of European Financial & Economic Crime Centre, Europol        

9:00 am
Tackling the Dark Underbelly of the Illegal Wildlife Trade A presentation by Araluen Schunmann, Director, Pangolin Crisis Fund

Anti-financial crime practitioners know that the illicit trade in wildlife has become a major source of illicit funds in the global criminal economy. But what do practitioners know about how the criminals conduct their business? In comparison to illicit activities such as drugs and human trafficking, the modus operandi of illicit wildlife traders is much less well-known. There are good reasons for this, of course, given the relative immaturity of the international effort to tackle the problem. But even so, we are learning – slowly – about how the wildlife traffickers operate.

In this presentation, Araluen Schunmann, Director of the Pangolin Crisis Fund for the Wildlife Conservation Network (WCN), will explore how the trade works, providing insights into the international supply chain for wildlife, the demand and supply that drive the illegal market, and the important role that corruption plays in enabling the trade. She will also explore how law enforcement agencies and NGOs seek to investigate these crimes, while providing a frank assessment of the roadblocks they face. What good can a SAR do against a sophisticated international network, and what prospects are there for the investigation and prosecution of traffickers at the top of the criminal organisations, rather than lower-level operatives who facilitate the trade on a day-to-day basis? Providing a balanced view of where we are in the fight, the presentation will not only explore emerging strategies for tackling the trade, but also address what else will need to change for the international community to have a significant impact.

Presented by Araluen Schunmann, Director of the Pangolin Crisis Fund, ‎Wildlife Conservation Network

9:45 am
Fighting Kleptopia -A conversation with Tom Burgis, author of ‘Kleptopia: How Dirty Money is Conquering the World’.

Even a decade ago, the emergence of kleptocracy – a political system where leaders use their positions of power to enrich themselves – was seen by those living in ‘developed’ states as being a marginal risk that affected only poor or undemocratic societies. However, as we have learned since then, no society – however well-established – is immune from the lure of financial and political corruption.

One of the leading journalists chronicling the progress of kleptocracy across the world is Tom Burgis, an award-winning reporter and a long-standing member of the Financial Times’ investigations team. In his most recent book, Kleptopia, published in 2020, Burgis exposes how seemingly disparate events, such as a massacre on the Kazakh steppe or a stolen election in Zimbabwe, can be linked to a hidden web of connections that touches centres of power not only in Beijing and the Kremlin, but also the City of London and, ultimately, the White House.

In this session, Burgis will discuss the inner workings of this growing global network of kleptocratic elites, and the efforts of quiet heroes seeking to highlight this problem, such as the compliance officer-turned-whistleblower Nigel Wilkins, who features in the book. Burgis also will explore how half-hearted government and private sector initiatives have failed to challenge the problems of corruption and illicit finance so far, and consider more effective ways to take the fight to the kleptocrats, now.  

Interview with Tom Burgis, Investigations correspondent, Financial Times

10:30 am
From Siloes to Systemic Solutions: FinCrime Utilities - Long term solutions?

FinCrime professionals often argue that one of the major challenges they face is the fragmentation of the anti-FinCrime effort: not only between the public and private sectors, but between firms themselves. With each individual business seeking to identify high-risk clients and suspicious activities through their own resources alone, it can be relatively simple for sophisticated financial criminals to work around the system. One idea often discussed has been that of ‘utilities’: institutions pooling their resources and working together to undertake their FinCrime obligations jointly. The most common experiments so far have been with KYC utilities in Asia-Pacific, Africa and Europe. Separately, a group of five major banks in the Netherlands has also started building the world’s first Transaction Monitoring utility.

These kinds of projects - combining data or taking a systemic, network view - should in theory improve the industry’s ability to understand and tackle common risks. However, so far, this has not been fully demonstrated, and utilities have also generated substantial practical issues of implementation. Some of these have been unique to the specific requirements of the project at hand, whether KYC or monitoring, while others appear to be more common. Integrating the data from multiple diverse institutions has proved a technical headache for some in the KYC space already, and in a world where personal data privacy is increasingly privileged, data-pooling has faced major challenges from developments such as the EU’s General Data Protection Regulation (GDPR).  Surveying this complex landscape, the panel will assess the potential value that utilities can bring to different aspects of the fight against FinCrime, and the balance between risk and reward that might come with such ambitious collaborations.

Host:

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research    


Panellists:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Helène Erftemeijer, KYC Lead, ING

Che Sidanius, Global Head of Financial Crime and Industry Affairs, Refinitiv

Lora von Ploetz, Director/Head of Global Financial Crime Unit, Commerzbank AG                                  

11:20 am
The Key to FinCrime? Encryption, Privacy Enhancing Technologies and the data-sharing challenge

A common refrain amongst FinCrime professionals is that it would be easier to take on the criminals if they were more readily able to share sensitive information between organisations. Whereas criminals have no barriers to worry about in this regard, those tasked with detecting and disrupting them have to follow closely the requirements of data and privacy law, which have often proved prohibitive.

For some time, the problem has been without a potential solution. However, over recent years, the development of advanced encryption techniques, often described as ‘Privacy Enhancing Technologies’ (PETs), have opened up new opportunities for smart data sharing. According to their proponents, PETs can help institutions combine and analyse sensitive data that remains can encrypted throughout – effectively ‘sharing’ without sharing.

The potential implications for financial intelligence partnerships are significant and have thus become a major topic of interest amongst FinCrime professionals. In this session, our experts will explore the promise of PETs: from the potential FinCrime ‘use cases’, the evidence of value and workability, to the practical challenges – from the technological to the regulatory – they might also bring.

Host:

Seán Doyle, Lead, Cybersecurity and Anti-Financial Crime, World Economic Forum

 
Panellists:

Rina Shainski, Co-founder and Chairwoman, Duality Technologies

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research

12:50 pm
FinCrime’s Wider Responsibility- Environmental, Social and Governance Reporting in FinCrime Compliance A presentation by Michael Rasmussen

In a world increasingly concerned with nurturing sustainability, businesses now take a greater interest in the wider impacts that they have on the environments and societies in which they operate. As part of this trend, Environmental, Social and Governance (ESG) reporting has become a common feature of how businesses seek to manage and explain their approach to these issues to regulators, investors, customers and employees.

Nonetheless, despite its recent spread, ESG reporting is often not fully understood, even in compliance tems. Although the issue of environmental impact is well-known, the full gamut of social concerns that need to be covered in ESG, from privacy, modern slavery, through to inclusion and diversity – are much less appreciated, as too is the role that governance needs to play in the management of financial crime risks such as fraud, bribery and corruption. To have an effective ESG program requires that financial crime compliance teams be a critical part of the reporting strategy.

In this session, Michael Rasmussen, aka ‘The GRC Pundit’, will help participants think through the essentials of an effective ESG program, and will cover: challenges of definition and scope; the clarification of regulatory and stakeholder requirements; the role that financial crime compliance teams need to play; and strategy and processes of ESG reporting. Michael is an internationally recognised commentator and consultant on Governance, Risk and Compliance (GRC) – a term he himself coined – and has over three decades of experience in the field. A popular presenter from our March conference, we are delighted to welcome him back

Presented by Michael Rasmussen, GRC Analyst & Pundit, GRC 20/20 Research

2:00 pm
The Real Ingredients of Virtual Compliance ‘Baking-in’ FinCrime good practice from the start

For entrepreneurs in any space there is often a desire to do things ‘differently’. Indeed, that is a prime motivation: to deliver a new product to customers. It can be tempting to focus on getting this right, providing a high-quality customer experience, and stimulating growth, to the exclusion of other concerns. Although compliance, regulation and risk management do not get ignored, they can slip down the list of priorities.

This has undoubtedly been a common challenge in the Virtual Assets sector, where innovators focused on developing new types of asset, product or service have sometimes found themselves dealing with issues of financial crime compliance last - with dire commercial and sometimes legal consequences. In some recent cases, the spread of stronger global AML/CFT requirements for the industry has led firms who did not factor such matters in from the start to go out of business. In other cases, failures to meet regulatory requirements have led to fines and regulatory censure.

If the Virtual Assets sector is to continue its remarkable growth, therefore, entrepreneurs and firms in the sector will need to develop sustainable ways in which to approach core compliance and risk management requirements from the start. In this session, our panel of experts will consider the ways in which Virtual Assets innovators have addressed these issues so far – successfully and otherwise – and seek to glean learning points for how Virtual Assets firms can ‘bake-in’ good practice, and develop sustainable FinCrime frameworks as an ingredient of long-term success.

Host:

• David Rowe-Francis, Founder, Praxis Compliance Consultants

Panellists:

Araba Eshun, Head of Compliance & MLRO, UK, Gemini Europe Limited

Caitlin Barnett, Director of Regulations and Compliance, Chainalysis                                                

2:50 pm
Crypto 2.0 – New ways of performing old tricks? Exploring Crypto Typologies with Nick Furneaux

Any sufficiently new technology can seem like magic to the uninitiated, and it can become easy to assume that its abuse by criminals is equally magical and just as perplexing. It can also become a natural next step to assume that there is a particular type of ‘crime’ inherent to the new technology in question.

Rarely in recent years have new technologies been so quickly framed in this way as blockchain and cryptocurrencies. FinCrime discourse has quickly assumed that not only is cryptocurrency inherently riskier than fiat currency, but that there is a particular form of distinctive crime – ‘crypto crime’ – that is intimately linked to it.

But despite these presumptions, the truth about the criminal abuse of cryptocurrency is considerably more prosaic. ‘Crypto crimes’ are in fact just good, old-fashioned crimes, with a new ‘virtual’ twist, according to Nick Furneaux, Managing Director of CSITech and author of Investigating Cryptocurrencies. In this session, Nick will follow up his popular talk from our March conference with an exploration of the classic criminal typologies that get applied to cryptocurrencies and provide potential investors with a range of issues to consider when dealing safely in this evolving market.

Presented by Nick Furneaux, MD at CSITech and CTO at Asset Reality                                                  

3:50 pm
Off the Crypto Rollercoaster Are stable coins and centralised digital currencies 'safe' alternatives?

In the face of soaring market values for a variety of cryptocurrencies, public authorities and established financial institutions across the world have been forced to start considering the implications of these assets’ wider usage. Cryptocurrencies are no longer seen to be a ‘fringe’ interest, or of little relevance to the wider economy.

Nonetheless, concerns continue about the perceived risks of market failure and abuse that come with the assets. Organisations in the public and private sectors are both trying to clarify their approaches to the issue. Some are rejecting crypto outright, while others are choosing to ride the rollercoaster. But between the extremes, others have been seeking to develop crypto in a more ‘risk friendly’ way. Private stablecoins – cryptocurrencies linked to the value of more tangible assets – are one proposed solution – while fully digitalised versions of pre-existing fiat currencies are another.

In this panel, our experts will explore the growing diversity of virtual and digital currencies, the likely future trends, and the growing role that governments and ‘big technology’ firms are seeking to play in the space. They will also ask whether these alternatives can really have the same market appeal as pure ‘crypto’ - without the potential risks.

4:40 pm
Scanning the Virtual Horizon The next steps for global Virtual Asset regulation

In March 2021, the Financial Action Task Force (FATF), the international standard setter for FinCrime, issued new guidelines on a risk-based approach to Virtual Assets and Virtual Asset Service Providers. Coming less than two years after its first guidelines on the area, the document has sought to clarify uncertainties, fill gaps, and update the rules in light of the fast-growing scope of the sector. Overall, the new guidelines have pointed towards a more stringent approach than before, with a widened definition of Virtual Assets, and additional references to stable coins, Decentralised Finance (DeFi) and Non-Fungible Tokens (NFT). Some FATF members have already starting taking a tougher line on the question, and those that have not are likely to follow suit in the near future.

But is this the right approach for Virtual Assets, or even the only approach? Is it possible to continue to apply a framework designed for fiat currencies to the virtual space? Or will a bespoke approach be required? In this panel, our speakers will review the current ‘state of play’ in the regulation of Virtual Assets, the philosophy behind regulators’ policies, and assess where regulators might go next. The panel will explore whether other regulatory models or bespoke alternatives might be applied to better effect, and the potential scope for regulatory innovation.

5:30 pm
Scams: Fuelling the Crypto Fire A presentation by Scott Johnson, Chainanalysis

In its 2021 Crypto Crime Report, Chainanalysis, a leading blockchain analysis company, found that scams – ranging from Darknet market abuse, extortion, phishing to Ponzi schemes – continue to be the highest-grossing forms of cryptocurrency-based crime, bringing in around $2.7 billion to criminals. Last year, scam-type crimes – especially fake investment schemes – were also affecting more individuals than ever before, with the number of separate payments to scam addresses rising from just over 5 to 7.3 million – a potential rise in victim numbers of more than 48%. Scams have always been big business for serious organised criminality, and the expansion of cryptocurrency usage has provided new options not only to make money, but to launder it too.In this session, we will be hearing from Scott Johnston, Head of Public Sector Outreach (EMEA) at Chainanalysis, the company behind the report, who will provide a realistic and evidence-driven overview of where we are with crypto-linked scamming. Scott – a former UK police officer with 18 years’ experience investigating serious organised crime, money laundering and emerging crypto threats – will help participants understand what the headline figures mean in practice, learning about 2020’s most significant scam-related cases and the likely trends in the crypto crime ecosystem in 2021. Scott will also explore how we can start to take ‘the fuel off the fire’, using blockchain analysis as a way to profile and track down scammers and identify new leads.

Presented by Scott Johnston, Head of Public Sector Operations, EMEA, Chainalysis                                                  

Tuesday 22nd June

8:00 am
A Talk on the Wild Side - A conversation on the Wildlife-FinCrime nexus with John Scanlon

The potential link between the illegal wildlife trade and the spread of COVID-19 has focused attention once again on the trafficking and exploitation of wild animals, as well as plants. Exotic animals can often bring incredible prices in illicit markets, and according to the UN, wildlife crime has become a “significant and specialised” form of transnational crime in its own right.

Australian lawyer John Scanlon has been one of the leading global voices against this trade, and currently holds three major positions with campaigning organisations: CEO of the Elephant Protection Initiative (EPI) Foundation, Chair of the Global Alliance to End Wildlife Crime, and Chair of the UK Government's Illegal Wildlife Trade Challenge Fund. He has also served as the Secretary-General of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) for nearly a decade between 2010-2018.

There are few campaigners as intimately aware of the realities of the illegal wildlife trade, and in this session, John will share his experiences of the fight, as well as his perspectives on how to go about tackling this pernicious problem more effectively. Looking to a dedicated and coordinated global effort, tougher regulation and enforcement, he argues that the illegal wildlife trade is “not a poor man’s crime”, and that governments need to focus on following dirty money in exactly the same way as with other major forms of serious organised criminality.

Interview with John E Scanlon AO, Chair, Global Initiative to End Wildlife Crime

9:00 am
Complying with Diversity Building an inclusive FinCrime profession

Critics often complain that the FinCrime compliance profession is something of a closed-shop for white, middle-class men who have worked for decades in the financial services sector, and dominate the top tiers of senior management in the field. This kind of characterisation is not wholly fair, of course. Increasing amounts of women are developing sustainable and successful careers in the industry, as too are those coming from a Black, Asian or Minority Ethnic (BAME) background. But most in the industry will admit that there is still a distance to go.

The industry also continues to be siloed in other ways, with financial services compliance still seen by many in the field as a ‘career for life’ that requires little input from other professional perspectives. This preconception has been challenged over the last decade too, by an influx of staff from public sector backgrounds such as law enforcement and intelligence, and increasing numbers of technically savvy individuals who work with data and advanced platforms. The rise of fintech has also played a role, bringing a wider range of young, talented individuals who want to challenge the ‘group think’ of pre-existing FinCrime approaches into the field.

In this session, our panellists will discuss the practical value that a diversity of skills and experience can bring to the execution of compliance and risk management, and consider the challenges that come with building and sustaining diverse teams. The panel will also identify good practice from both within and beyond the sector, to help firms get the best out of their people, whatever their backgrounds.

10:30 am
Moving the Needle - Defining, measuring, and improving FinCrime effectiveness

Many key players in the FinCrime world have been seeking to define the term ‘effectiveness’. Following the lead of the global standard setters, the Financial Action Task Force (FATF), most regulators have sought to assess the issue through subjective evaluations of ‘how well’ businesses meet their compliance obligations. Recently, the US federal government’s Financial Crimes Enforcement Network (FinCEN) has sought to take a more measurable approach, suggesting that an ‘effective’ FinCrime programme delivers ‘useful’ Suspicious Activity Reports (SARs) – in other words, financial intelligence that materially helps law enforcement investigations.

But despite such attempts to take a granular and concrete approach, the meaning of the term ‘effectiveness’ is still ambiguous for stakeholders in both the public and private sectors and is often re-interpreted to mean measuring what is easy – especially outputs and efficiency – rather what matters – outcomes and impact. In this panel therefore, we bring together a number of leading FinCrime practitioners to scrutinise what the term effectiveness can – and more importantly should – mean in the for the stakeholders in the FinCrime world, and explore pragmatic and practical ways in which all stakeholders can help ‘move the needle’ in a positive direction

Host:
John Cusack, Chair, Global Coalition to Fight Financial Crime
Panellists:
Geraldine Lawlor, Global Lead Partner for Financial Crime, KPMG LLP
Dr Ronald Pol, Director and Principal, TeamFactors.com and AMLassurance.com
Gemma Rogers, Co-founder, FINTRAIL
Daniel Thelesklaf, Director, Finance Against Slavery and Trafficking, UN University – Centre for Policy Research
Vishal Marria, CEO, Quantexa
                                   
11:20 am
Cultural Capital Can we achieve a positive FinCrime ‘compliance culture’?

For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.

12:10 pm
The Last Lines of Defence Strengthening the professions’ fight against FinCrime

Most public attention on the private sector’s efforts against FinCrime is devoted to the role of financial institutions, and in particular, banks. This is quite logical, given the centrality of their roles as the gatekeepers of the financial system, and the parts they have unwittingly played in moving illicit funds around the global economy.

However, FinCrime does not touch the financial sector alone, and the vulnerability of professions such as lawyers and accountants to becoming the tools of financial criminality has become more apparent in recent years. Estate agents’ services have also been abused by criminals seeking to ‘integrate’ illicit funds into the legitimate economy – indeed, the role illicit cash has played in property price booms has been widely reported. At the same time, the professions are still relatively minor reporters of suspicious activities to the authorities. Despite the warning signs, it does not appear that the professions have yet taken the issue as seriously as they should.

In this panel, our experts examine how financial criminals have made use of a variety of professional services to protect and enjoy their illicit funds, and ask why, so far, many firms in those sectors have failed to take FinCrime seriously. The panel will also consider ways in which regulators can encourage a more proactive approach, and how the wider private sector community can bring the professions into the fold.

Host:

Matthew Redhead, Associate Fellow, RUSI.


Panellists:

Dr Anna Bradshaw, Partner, Peters & Peters Solicitors LLP.
Dr Katie Benson, Lecturer in Criminology, Lancaster University.                                                    

1:00 pm
Above the Law? The challenge of bringing financial criminals to justice

The social restrictions of the COVID-19 pandemic have been a major impediment to financial criminals, who rely on easy access to the financial system to move dirty money. Law enforcement agencies – seeking to make the best of a difficult situation – have been able to take advantage, seizing large amounts of illicit cash that would otherwise have been laundered through the system, or smuggled to high-risk jurisdictions.

Nonetheless, these recent successes - often highlighted in the media - should not detract from the underlying reality that all law enforcement agencies are struggling to reduce the scale and scope of FinCrime. According to most reliable global estimates, no more than 1-2% of illicit funds are ever retrieved by the authorities – an astonishingly low figure.

Our panel of experts will probe into the reasons behind this apparent failure to retrieve funds and bring financial criminals to justice, exploring systemic weaknesses and vulnerabilities that generate such poor operational outcomes. At the same time, the panel will also explore the potential of new initiatives, such as Unexplained Wealth Orders (UWOs), to rebalance the playing field, and consider new ways in which the private sector could support the authorities’ campaign against financial criminals.

Host:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Panellists:

Aidan Larkin, CEO, Asset Reality

Carmel King, Director, Insolvency and Asset Recovery, Grant Thornton UK LLP

Sarah Hargreaves, ACI, ACE, Director of Training - International, Exterro      

2:30 pm
United We Stand The potential for integrated FinCrime teams and controls

The problem of fragmentation affects the world of FinCrime in many ways. Within compliance and risk management functions, the past isolation of AML, fraud and sanctions teams has led to key risks falling between the institutional gaps – a problem exacerbated when the teams use different platforms and data streams. FinCrime measures as conventionally applied also have temporal as well as organisational gaps, with retrospective monitoring leading to delays in suspicious activity reporting, and slow KYC refresh cycles meaning that customer risk profiles remain woefully out of date.

Many businesses are thus now seeking ways to make their FinCrime frameworks more responsive to real-time demands. Some larger financial institutions have restructured their FinCrime ‘estates’ to bring previously separate teams together and deployed new technologies to create a more integrated approach: concepts such as ‘seamless AML’ and ‘perpetual KYC’ have now started moving from idea to reality.

In this panel, our experts will investigate the problems of fragmentation and delay in traditional FinCrime frameworks and explore the progress that innovators in the financial services sector have made so far in creating a more coherent response, especially with new technologies. They will also consider where such changes are leading, and whether it is realistic to expect we can make our own frameworks as agile and coherent as those of the financial criminals themselves.

3:20 pm
Beyond the Banking Bubble Leveraging technology lessons from other industries

In the last few years, financial services providers and Regulatory Technology (RegTech) firms have talked a great deal about the deployment of new data-driven technologies, usually with a focus on automation and supervised machine learning to core compliance tasks such as sanctions screening and transaction monitoring. However, in spite of the competitiveness between RegTechs, platforms have sometimes been less advanced than they might seem, given their need to pass tight regulatory validation requirements.

In contrast, other industries and sectors are finding ambitious ways in which to leverage new technologies with fewer constraints. In healthcare, for example, providers are increasingly using more advanced supervised and unsupervised machine learning models, allowing Artificial Intelligence (AI) to play greater roles in decision-making in diagnosis and prescription. If a ‘trust but verify’ approach can be applied to human health, there are questions to ask about why we cannot take the same stance when it comes to financial crime risk.

In this session, our panel of experts will therefore take us beyond the boundaries of the FinCrime world, to explore the ways in which new technologies are being applied to other industries and sectors; consider how their techniques might be translated into the fight against financial crime; and review the ways in which FinCrime regulators too could learn from their counterparts in other sectors.

4:10 pm
Pushing for the RegTech Revolution Removing the barriers to adoption in FinCrime

In a recent report, the City of London Corporation has argued that the financial services sector needs to leverage new regulatory technologies (RegTech) to meet their obligations and fight financial crime. The report follows a succession of other statements from leading regulators in the US, Europe and Asia-Pacific, all making similar points.

However, as the City of London also notes, the take up of RegTech – though comparatively better in the FinCrime space than other areas – is still limited overall. A lack of practical rather than rhetorical regulator support has been proposed as one cause for this, and there are likely to be other barriers too. Some of the most innovative RegTechs are relatively small or young firms that find it difficult to satisfy the risk requirements of large and mature financial institutions. Even when the solution on offer is a good fit, it can sometimes be impractical for either side to work together.

In this session, the panellists will provide a pragmatic view on the state of RegTech adoption in the industry and seek to get to the root causes of its currently slow pace, looking at regulatory, commercial as well as technological points of friction. The panel will also look at ways the current initiatives to support RegTech, such as regulatory sandboxes and ‘Tech Sprints’, might be enhanced and expanded in order to ensure the sector meets its full potential in the future.

Host:

Christopher Woolard CBE, Partner, EMEIA Financial Services Consulting & Chair, EY Global Regulatory Network, EY LLP

Panellists:

Dr Sian Lewin, Co-Founder and Head of Client Delivery, RegTech Associates

Francesca Hopwood Road, Head of RegTech & Advanced Analytics, FCA

8:15 am
FinCrime’s Pivotal Moment - A conversation with Burkhard Mühl, Head of the European Financial & Economic Crime Centre, Europol

The 2021 Serious and Organised Crime Threat Assessment (SOCTA) from Europol, the EU’s policing agency, made for sombre reading. According to the report, organised criminality in Europe is more complex and fluid than ever before, with different criminal gangs working together ‘as needed’, on the basis of mutual self-interest. Unlike the old-fashioned ‘Godfather’ model of organised criminality imagined in films and TV, modern master criminals are now as agile and collaborative as the entrepreneurs of the technology sector. Laundering the funds generated by these illicit criminal activities has become as equally sophisticated as the predicate crimes themselves, with professionalised networks, often operating through legitimate business structures, insulated from effective disruption by systemic corruption of individuals in the public sector, financial institutions and professions. As a consequence, the management of illicit finance has become deeply rooted in societies and economies, with its scale and complexity probably significantly greater than previously thought.

In this interview, we explore these issues in depth with Burkhard Mühl, since December 2020 the Head of the newly created European Financial & Economic Crime Centre (EFECC) at Europol. Herr Mühl – a 35-year veteran of Austrian and European law enforcement – believes that serious and organised crime and illicit finance are now major challenges for the EU, and therefore need to be addressed not only with new vigour, but a more strategic approach that targets the ‘high value’ kingpins at the centres of the networks. He also contends that to put organised criminals and money launderers on the defensive, law enforcement agencies and their partners in the private sector will need to learn lessons from their opponents’ success – by becoming ‘masters of collaboration’ in their own right.

Interview with Burkhard Mühl, Head of European Financial & Economic Crime Centre, Europol        

9:00 am
Tackling the Dark Underbelly of the Illegal Wildlife Trade A presentation by Araluen Schunmann, Director, Pangolin Crisis Fund

Anti-financial crime practitioners know that the illicit trade in wildlife has become a major source of illicit funds in the global criminal economy. But what do practitioners know about how the criminals conduct their business? In comparison to illicit activities such as drugs and human trafficking, the modus operandi of illicit wildlife traders is much less well-known. There are good reasons for this, of course, given the relative immaturity of the international effort to tackle the problem. But even so, we are learning – slowly – about how the wildlife traffickers operate.

In this presentation, Araluen Schunmann, Director of the Pangolin Crisis Fund for the Wildlife Conservation Network (WCN), will explore how the trade works, providing insights into the international supply chain for wildlife, the demand and supply that drive the illegal market, and the important role that corruption plays in enabling the trade. She will also explore how law enforcement agencies and NGOs seek to investigate these crimes, while providing a frank assessment of the roadblocks they face. What good can a SAR do against a sophisticated international network, and what prospects are there for the investigation and prosecution of traffickers at the top of the criminal organisations, rather than lower-level operatives who facilitate the trade on a day-to-day basis? Providing a balanced view of where we are in the fight, the presentation will not only explore emerging strategies for tackling the trade, but also address what else will need to change for the international community to have a significant impact.

Presented by Araluen Schunmann, Director of the Pangolin Crisis Fund, ‎Wildlife Conservation Network

9:45 am
Fighting Kleptopia -A conversation with Tom Burgis, author of ‘Kleptopia: How Dirty Money is Conquering the World’.

Even a decade ago, the emergence of kleptocracy – a political system where leaders use their positions of power to enrich themselves – was seen by those living in ‘developed’ states as being a marginal risk that affected only poor or undemocratic societies. However, as we have learned since then, no society – however well-established – is immune from the lure of financial and political corruption.

One of the leading journalists chronicling the progress of kleptocracy across the world is Tom Burgis, an award-winning reporter and a long-standing member of the Financial Times’ investigations team. In his most recent book, Kleptopia, published in 2020, Burgis exposes how seemingly disparate events, such as a massacre on the Kazakh steppe or a stolen election in Zimbabwe, can be linked to a hidden web of connections that touches centres of power not only in Beijing and the Kremlin, but also the City of London and, ultimately, the White House.

In this session, Burgis will discuss the inner workings of this growing global network of kleptocratic elites, and the efforts of quiet heroes seeking to highlight this problem, such as the compliance officer-turned-whistleblower Nigel Wilkins, who features in the book. Burgis also will explore how half-hearted government and private sector initiatives have failed to challenge the problems of corruption and illicit finance so far, and consider more effective ways to take the fight to the kleptocrats, now.  

Interview with Tom Burgis, Investigations correspondent, Financial Times

10:30 am
From Siloes to Systemic Solutions: FinCrime Utilities - Long term solutions?

FinCrime professionals often argue that one of the major challenges they face is the fragmentation of the anti-FinCrime effort: not only between the public and private sectors, but between firms themselves. With each individual business seeking to identify high-risk clients and suspicious activities through their own resources alone, it can be relatively simple for sophisticated financial criminals to work around the system. One idea often discussed has been that of ‘utilities’: institutions pooling their resources and working together to undertake their FinCrime obligations jointly. The most common experiments so far have been with KYC utilities in Asia-Pacific, Africa and Europe. Separately, a group of five major banks in the Netherlands has also started building the world’s first Transaction Monitoring utility.

These kinds of projects - combining data or taking a systemic, network view - should in theory improve the industry’s ability to understand and tackle common risks. However, so far, this has not been fully demonstrated, and utilities have also generated substantial practical issues of implementation. Some of these have been unique to the specific requirements of the project at hand, whether KYC or monitoring, while others appear to be more common. Integrating the data from multiple diverse institutions has proved a technical headache for some in the KYC space already, and in a world where personal data privacy is increasingly privileged, data-pooling has faced major challenges from developments such as the EU’s General Data Protection Regulation (GDPR).  Surveying this complex landscape, the panel will assess the potential value that utilities can bring to different aspects of the fight against FinCrime, and the balance between risk and reward that might come with such ambitious collaborations.

Host:

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research    


Panellists:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Helène Erftemeijer, KYC Lead, ING

Che Sidanius, Global Head of Financial Crime and Industry Affairs, Refinitiv

Lora von Ploetz, Director/Head of Global Financial Crime Unit, Commerzbank AG                                  

11:20 am
The Key to FinCrime? Encryption, Privacy Enhancing Technologies and the data-sharing challenge

A common refrain amongst FinCrime professionals is that it would be easier to take on the criminals if they were more readily able to share sensitive information between organisations. Whereas criminals have no barriers to worry about in this regard, those tasked with detecting and disrupting them have to follow closely the requirements of data and privacy law, which have often proved prohibitive.

For some time, the problem has been without a potential solution. However, over recent years, the development of advanced encryption techniques, often described as ‘Privacy Enhancing Technologies’ (PETs), have opened up new opportunities for smart data sharing. According to their proponents, PETs can help institutions combine and analyse sensitive data that remains can encrypted throughout – effectively ‘sharing’ without sharing.

The potential implications for financial intelligence partnerships are significant and have thus become a major topic of interest amongst FinCrime professionals. In this session, our experts will explore the promise of PETs: from the potential FinCrime ‘use cases’, the evidence of value and workability, to the practical challenges – from the technological to the regulatory – they might also bring.

Host:

Seán Doyle, Lead, Cybersecurity and Anti-Financial Crime, World Economic Forum

 
Panellists:

Rina Shainski, Co-founder and Chairwoman, Duality Technologies

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research

12:50 pm
FinCrime’s Wider Responsibility- Environmental, Social and Governance Reporting in FinCrime Compliance A presentation by Michael Rasmussen

In a world increasingly concerned with nurturing sustainability, businesses now take a greater interest in the wider impacts that they have on the environments and societies in which they operate. As part of this trend, Environmental, Social and Governance (ESG) reporting has become a common feature of how businesses seek to manage and explain their approach to these issues to regulators, investors, customers and employees.

Nonetheless, despite its recent spread, ESG reporting is often not fully understood, even in compliance tems. Although the issue of environmental impact is well-known, the full gamut of social concerns that need to be covered in ESG, from privacy, modern slavery, through to inclusion and diversity – are much less appreciated, as too is the role that governance needs to play in the management of financial crime risks such as fraud, bribery and corruption. To have an effective ESG program requires that financial crime compliance teams be a critical part of the reporting strategy.

In this session, Michael Rasmussen, aka ‘The GRC Pundit’, will help participants think through the essentials of an effective ESG program, and will cover: challenges of definition and scope; the clarification of regulatory and stakeholder requirements; the role that financial crime compliance teams need to play; and strategy and processes of ESG reporting. Michael is an internationally recognised commentator and consultant on Governance, Risk and Compliance (GRC) – a term he himself coined – and has over three decades of experience in the field. A popular presenter from our March conference, we are delighted to welcome him back

Presented by Michael Rasmussen, GRC Analyst & Pundit, GRC 20/20 Research

2:00 pm
The Real Ingredients of Virtual Compliance ‘Baking-in’ FinCrime good practice from the start

For entrepreneurs in any space there is often a desire to do things ‘differently’. Indeed, that is a prime motivation: to deliver a new product to customers. It can be tempting to focus on getting this right, providing a high-quality customer experience, and stimulating growth, to the exclusion of other concerns. Although compliance, regulation and risk management do not get ignored, they can slip down the list of priorities.

This has undoubtedly been a common challenge in the Virtual Assets sector, where innovators focused on developing new types of asset, product or service have sometimes found themselves dealing with issues of financial crime compliance last - with dire commercial and sometimes legal consequences. In some recent cases, the spread of stronger global AML/CFT requirements for the industry has led firms who did not factor such matters in from the start to go out of business. In other cases, failures to meet regulatory requirements have led to fines and regulatory censure.

If the Virtual Assets sector is to continue its remarkable growth, therefore, entrepreneurs and firms in the sector will need to develop sustainable ways in which to approach core compliance and risk management requirements from the start. In this session, our panel of experts will consider the ways in which Virtual Assets innovators have addressed these issues so far – successfully and otherwise – and seek to glean learning points for how Virtual Assets firms can ‘bake-in’ good practice, and develop sustainable FinCrime frameworks as an ingredient of long-term success.

Host:

• David Rowe-Francis, Founder, Praxis Compliance Consultants

Panellists:

Araba Eshun, Head of Compliance & MLRO, UK, Gemini Europe Limited

Caitlin Barnett, Director of Regulations and Compliance, Chainalysis                                                

2:50 pm
Crypto 2.0 – New ways of performing old tricks? Exploring Crypto Typologies with Nick Furneaux

Any sufficiently new technology can seem like magic to the uninitiated, and it can become easy to assume that its abuse by criminals is equally magical and just as perplexing. It can also become a natural next step to assume that there is a particular type of ‘crime’ inherent to the new technology in question.

Rarely in recent years have new technologies been so quickly framed in this way as blockchain and cryptocurrencies. FinCrime discourse has quickly assumed that not only is cryptocurrency inherently riskier than fiat currency, but that there is a particular form of distinctive crime – ‘crypto crime’ – that is intimately linked to it.

But despite these presumptions, the truth about the criminal abuse of cryptocurrency is considerably more prosaic. ‘Crypto crimes’ are in fact just good, old-fashioned crimes, with a new ‘virtual’ twist, according to Nick Furneaux, Managing Director of CSITech and author of Investigating Cryptocurrencies. In this session, Nick will follow up his popular talk from our March conference with an exploration of the classic criminal typologies that get applied to cryptocurrencies and provide potential investors with a range of issues to consider when dealing safely in this evolving market.

Presented by Nick Furneaux, MD at CSITech and CTO at Asset Reality                                                  

3:50 pm
Off the Crypto Rollercoaster Are stable coins and centralised digital currencies 'safe' alternatives?

In the face of soaring market values for a variety of cryptocurrencies, public authorities and established financial institutions across the world have been forced to start considering the implications of these assets’ wider usage. Cryptocurrencies are no longer seen to be a ‘fringe’ interest, or of little relevance to the wider economy.

Nonetheless, concerns continue about the perceived risks of market failure and abuse that come with the assets. Organisations in the public and private sectors are both trying to clarify their approaches to the issue. Some are rejecting crypto outright, while others are choosing to ride the rollercoaster. But between the extremes, others have been seeking to develop crypto in a more ‘risk friendly’ way. Private stablecoins – cryptocurrencies linked to the value of more tangible assets – are one proposed solution – while fully digitalised versions of pre-existing fiat currencies are another.

In this panel, our experts will explore the growing diversity of virtual and digital currencies, the likely future trends, and the growing role that governments and ‘big technology’ firms are seeking to play in the space. They will also ask whether these alternatives can really have the same market appeal as pure ‘crypto’ - without the potential risks.

4:40 pm
Scanning the Virtual Horizon The next steps for global Virtual Asset regulation

In March 2021, the Financial Action Task Force (FATF), the international standard setter for FinCrime, issued new guidelines on a risk-based approach to Virtual Assets and Virtual Asset Service Providers. Coming less than two years after its first guidelines on the area, the document has sought to clarify uncertainties, fill gaps, and update the rules in light of the fast-growing scope of the sector. Overall, the new guidelines have pointed towards a more stringent approach than before, with a widened definition of Virtual Assets, and additional references to stable coins, Decentralised Finance (DeFi) and Non-Fungible Tokens (NFT). Some FATF members have already starting taking a tougher line on the question, and those that have not are likely to follow suit in the near future.

But is this the right approach for Virtual Assets, or even the only approach? Is it possible to continue to apply a framework designed for fiat currencies to the virtual space? Or will a bespoke approach be required? In this panel, our speakers will review the current ‘state of play’ in the regulation of Virtual Assets, the philosophy behind regulators’ policies, and assess where regulators might go next. The panel will explore whether other regulatory models or bespoke alternatives might be applied to better effect, and the potential scope for regulatory innovation.

5:30 pm
Scams: Fuelling the Crypto Fire A presentation by Scott Johnson, Chainanalysis

In its 2021 Crypto Crime Report, Chainanalysis, a leading blockchain analysis company, found that scams – ranging from Darknet market abuse, extortion, phishing to Ponzi schemes – continue to be the highest-grossing forms of cryptocurrency-based crime, bringing in around $2.7 billion to criminals. Last year, scam-type crimes – especially fake investment schemes – were also affecting more individuals than ever before, with the number of separate payments to scam addresses rising from just over 5 to 7.3 million – a potential rise in victim numbers of more than 48%. Scams have always been big business for serious organised criminality, and the expansion of cryptocurrency usage has provided new options not only to make money, but to launder it too.In this session, we will be hearing from Scott Johnston, Head of Public Sector Outreach (EMEA) at Chainanalysis, the company behind the report, who will provide a realistic and evidence-driven overview of where we are with crypto-linked scamming. Scott – a former UK police officer with 18 years’ experience investigating serious organised crime, money laundering and emerging crypto threats – will help participants understand what the headline figures mean in practice, learning about 2020’s most significant scam-related cases and the likely trends in the crypto crime ecosystem in 2021. Scott will also explore how we can start to take ‘the fuel off the fire’, using blockchain analysis as a way to profile and track down scammers and identify new leads.

Presented by Scott Johnston, Head of Public Sector Operations, EMEA, Chainalysis                                                  

Tuesday 22nd June

9:00 am
Tackling the Dark Underbelly of the Illegal Wildlife Trade A presentation by Araluen Schunmann, Director, Pangolin Crisis Fund

Anti-financial crime practitioners know that the illicit trade in wildlife has become a major source of illicit funds in the global criminal economy. But what do practitioners know about how the criminals conduct their business? In comparison to illicit activities such as drugs and human trafficking, the modus operandi of illicit wildlife traders is much less well-known. There are good reasons for this, of course, given the relative immaturity of the international effort to tackle the problem. But even so, we are learning – slowly – about how the wildlife traffickers operate.

In this presentation, Araluen Schunmann, Director of the Pangolin Crisis Fund for the Wildlife Conservation Network (WCN), will explore how the trade works, providing insights into the international supply chain for wildlife, the demand and supply that drive the illegal market, and the important role that corruption plays in enabling the trade. She will also explore how law enforcement agencies and NGOs seek to investigate these crimes, while providing a frank assessment of the roadblocks they face. What good can a SAR do against a sophisticated international network, and what prospects are there for the investigation and prosecution of traffickers at the top of the criminal organisations, rather than lower-level operatives who facilitate the trade on a day-to-day basis? Providing a balanced view of where we are in the fight, the presentation will not only explore emerging strategies for tackling the trade, but also address what else will need to change for the international community to have a significant impact.

Presented by Araluen Schunmann, Director of the Pangolin Crisis Fund, ‎Wildlife Conservation Network

9:45 am
Fighting Kleptopia -A conversation with Tom Burgis, author of ‘Kleptopia: How Dirty Money is Conquering the World’.

Even a decade ago, the emergence of kleptocracy – a political system where leaders use their positions of power to enrich themselves – was seen by those living in ‘developed’ states as being a marginal risk that affected only poor or undemocratic societies. However, as we have learned since then, no society – however well-established – is immune from the lure of financial and political corruption.

One of the leading journalists chronicling the progress of kleptocracy across the world is Tom Burgis, an award-winning reporter and a long-standing member of the Financial Times’ investigations team. In his most recent book, Kleptopia, published in 2020, Burgis exposes how seemingly disparate events, such as a massacre on the Kazakh steppe or a stolen election in Zimbabwe, can be linked to a hidden web of connections that touches centres of power not only in Beijing and the Kremlin, but also the City of London and, ultimately, the White House.

In this session, Burgis will discuss the inner workings of this growing global network of kleptocratic elites, and the efforts of quiet heroes seeking to highlight this problem, such as the compliance officer-turned-whistleblower Nigel Wilkins, who features in the book. Burgis also will explore how half-hearted government and private sector initiatives have failed to challenge the problems of corruption and illicit finance so far, and consider more effective ways to take the fight to the kleptocrats, now.  

Interview with Tom Burgis, Investigations correspondent, Financial Times

5:30 pm
Scams: Fuelling the Crypto Fire A presentation by Scott Johnson, Chainanalysis

In its 2021 Crypto Crime Report, Chainanalysis, a leading blockchain analysis company, found that scams – ranging from Darknet market abuse, extortion, phishing to Ponzi schemes – continue to be the highest-grossing forms of cryptocurrency-based crime, bringing in around $2.7 billion to criminals. Last year, scam-type crimes – especially fake investment schemes – were also affecting more individuals than ever before, with the number of separate payments to scam addresses rising from just over 5 to 7.3 million – a potential rise in victim numbers of more than 48%. Scams have always been big business for serious organised criminality, and the expansion of cryptocurrency usage has provided new options not only to make money, but to launder it too.In this session, we will be hearing from Scott Johnston, Head of Public Sector Outreach (EMEA) at Chainanalysis, the company behind the report, who will provide a realistic and evidence-driven overview of where we are with crypto-linked scamming. Scott – a former UK police officer with 18 years’ experience investigating serious organised crime, money laundering and emerging crypto threats – will help participants understand what the headline figures mean in practice, learning about 2020’s most significant scam-related cases and the likely trends in the crypto crime ecosystem in 2021. Scott will also explore how we can start to take ‘the fuel off the fire’, using blockchain analysis as a way to profile and track down scammers and identify new leads.

Presented by Scott Johnston, Head of Public Sector Operations, EMEA, Chainalysis                                                  

12:50 pm
FinCrime’s Wider Responsibility- Environmental, Social and Governance Reporting in FinCrime Compliance A presentation by Michael Rasmussen

In a world increasingly concerned with nurturing sustainability, businesses now take a greater interest in the wider impacts that they have on the environments and societies in which they operate. As part of this trend, Environmental, Social and Governance (ESG) reporting has become a common feature of how businesses seek to manage and explain their approach to these issues to regulators, investors, customers and employees.

Nonetheless, despite its recent spread, ESG reporting is often not fully understood, even in compliance tems. Although the issue of environmental impact is well-known, the full gamut of social concerns that need to be covered in ESG, from privacy, modern slavery, through to inclusion and diversity – are much less appreciated, as too is the role that governance needs to play in the management of financial crime risks such as fraud, bribery and corruption. To have an effective ESG program requires that financial crime compliance teams be a critical part of the reporting strategy.

In this session, Michael Rasmussen, aka ‘The GRC Pundit’, will help participants think through the essentials of an effective ESG program, and will cover: challenges of definition and scope; the clarification of regulatory and stakeholder requirements; the role that financial crime compliance teams need to play; and strategy and processes of ESG reporting. Michael is an internationally recognised commentator and consultant on Governance, Risk and Compliance (GRC) – a term he himself coined – and has over three decades of experience in the field. A popular presenter from our March conference, we are delighted to welcome him back

Presented by Michael Rasmussen, GRC Analyst & Pundit, GRC 20/20 Research

8:15 am
FinCrime’s Pivotal Moment - A conversation with Burkhard Mühl, Head of the European Financial & Economic Crime Centre, Europol

The 2021 Serious and Organised Crime Threat Assessment (SOCTA) from Europol, the EU’s policing agency, made for sombre reading. According to the report, organised criminality in Europe is more complex and fluid than ever before, with different criminal gangs working together ‘as needed’, on the basis of mutual self-interest. Unlike the old-fashioned ‘Godfather’ model of organised criminality imagined in films and TV, modern master criminals are now as agile and collaborative as the entrepreneurs of the technology sector. Laundering the funds generated by these illicit criminal activities has become as equally sophisticated as the predicate crimes themselves, with professionalised networks, often operating through legitimate business structures, insulated from effective disruption by systemic corruption of individuals in the public sector, financial institutions and professions. As a consequence, the management of illicit finance has become deeply rooted in societies and economies, with its scale and complexity probably significantly greater than previously thought.

In this interview, we explore these issues in depth with Burkhard Mühl, since December 2020 the Head of the newly created European Financial & Economic Crime Centre (EFECC) at Europol. Herr Mühl – a 35-year veteran of Austrian and European law enforcement – believes that serious and organised crime and illicit finance are now major challenges for the EU, and therefore need to be addressed not only with new vigour, but a more strategic approach that targets the ‘high value’ kingpins at the centres of the networks. He also contends that to put organised criminals and money launderers on the defensive, law enforcement agencies and their partners in the private sector will need to learn lessons from their opponents’ success – by becoming ‘masters of collaboration’ in their own right.

Interview with Burkhard Mühl, Head of European Financial & Economic Crime Centre, Europol        

9:00 am
Complying with Diversity Building an inclusive FinCrime profession

Critics often complain that the FinCrime compliance profession is something of a closed-shop for white, middle-class men who have worked for decades in the financial services sector, and dominate the top tiers of senior management in the field. This kind of characterisation is not wholly fair, of course. Increasing amounts of women are developing sustainable and successful careers in the industry, as too are those coming from a Black, Asian or Minority Ethnic (BAME) background. But most in the industry will admit that there is still a distance to go.

The industry also continues to be siloed in other ways, with financial services compliance still seen by many in the field as a ‘career for life’ that requires little input from other professional perspectives. This preconception has been challenged over the last decade too, by an influx of staff from public sector backgrounds such as law enforcement and intelligence, and increasing numbers of technically savvy individuals who work with data and advanced platforms. The rise of fintech has also played a role, bringing a wider range of young, talented individuals who want to challenge the ‘group think’ of pre-existing FinCrime approaches into the field.

In this session, our panellists will discuss the practical value that a diversity of skills and experience can bring to the execution of compliance and risk management, and consider the challenges that come with building and sustaining diverse teams. The panel will also identify good practice from both within and beyond the sector, to help firms get the best out of their people, whatever their backgrounds.

4:40 pm
Scanning the Virtual Horizon The next steps for global Virtual Asset regulation

In March 2021, the Financial Action Task Force (FATF), the international standard setter for FinCrime, issued new guidelines on a risk-based approach to Virtual Assets and Virtual Asset Service Providers. Coming less than two years after its first guidelines on the area, the document has sought to clarify uncertainties, fill gaps, and update the rules in light of the fast-growing scope of the sector. Overall, the new guidelines have pointed towards a more stringent approach than before, with a widened definition of Virtual Assets, and additional references to stable coins, Decentralised Finance (DeFi) and Non-Fungible Tokens (NFT). Some FATF members have already starting taking a tougher line on the question, and those that have not are likely to follow suit in the near future.

But is this the right approach for Virtual Assets, or even the only approach? Is it possible to continue to apply a framework designed for fiat currencies to the virtual space? Or will a bespoke approach be required? In this panel, our speakers will review the current ‘state of play’ in the regulation of Virtual Assets, the philosophy behind regulators’ policies, and assess where regulators might go next. The panel will explore whether other regulatory models or bespoke alternatives might be applied to better effect, and the potential scope for regulatory innovation.

3:50 pm
Off the Crypto Rollercoaster Are stable coins and centralised digital currencies 'safe' alternatives?

In the face of soaring market values for a variety of cryptocurrencies, public authorities and established financial institutions across the world have been forced to start considering the implications of these assets’ wider usage. Cryptocurrencies are no longer seen to be a ‘fringe’ interest, or of little relevance to the wider economy.

Nonetheless, concerns continue about the perceived risks of market failure and abuse that come with the assets. Organisations in the public and private sectors are both trying to clarify their approaches to the issue. Some are rejecting crypto outright, while others are choosing to ride the rollercoaster. But between the extremes, others have been seeking to develop crypto in a more ‘risk friendly’ way. Private stablecoins – cryptocurrencies linked to the value of more tangible assets – are one proposed solution – while fully digitalised versions of pre-existing fiat currencies are another.

In this panel, our experts will explore the growing diversity of virtual and digital currencies, the likely future trends, and the growing role that governments and ‘big technology’ firms are seeking to play in the space. They will also ask whether these alternatives can really have the same market appeal as pure ‘crypto’ - without the potential risks.

2:50 pm
Crypto 2.0 – New ways of performing old tricks? Exploring Crypto Typologies with Nick Furneaux

Any sufficiently new technology can seem like magic to the uninitiated, and it can become easy to assume that its abuse by criminals is equally magical and just as perplexing. It can also become a natural next step to assume that there is a particular type of ‘crime’ inherent to the new technology in question.

Rarely in recent years have new technologies been so quickly framed in this way as blockchain and cryptocurrencies. FinCrime discourse has quickly assumed that not only is cryptocurrency inherently riskier than fiat currency, but that there is a particular form of distinctive crime – ‘crypto crime’ – that is intimately linked to it.

But despite these presumptions, the truth about the criminal abuse of cryptocurrency is considerably more prosaic. ‘Crypto crimes’ are in fact just good, old-fashioned crimes, with a new ‘virtual’ twist, according to Nick Furneaux, Managing Director of CSITech and author of Investigating Cryptocurrencies. In this session, Nick will follow up his popular talk from our March conference with an exploration of the classic criminal typologies that get applied to cryptocurrencies and provide potential investors with a range of issues to consider when dealing safely in this evolving market.

Presented by Nick Furneaux, MD at CSITech and CTO at Asset Reality                                                  

2:00 pm
The Real Ingredients of Virtual Compliance ‘Baking-in’ FinCrime good practice from the start

For entrepreneurs in any space there is often a desire to do things ‘differently’. Indeed, that is a prime motivation: to deliver a new product to customers. It can be tempting to focus on getting this right, providing a high-quality customer experience, and stimulating growth, to the exclusion of other concerns. Although compliance, regulation and risk management do not get ignored, they can slip down the list of priorities.

This has undoubtedly been a common challenge in the Virtual Assets sector, where innovators focused on developing new types of asset, product or service have sometimes found themselves dealing with issues of financial crime compliance last - with dire commercial and sometimes legal consequences. In some recent cases, the spread of stronger global AML/CFT requirements for the industry has led firms who did not factor such matters in from the start to go out of business. In other cases, failures to meet regulatory requirements have led to fines and regulatory censure.

If the Virtual Assets sector is to continue its remarkable growth, therefore, entrepreneurs and firms in the sector will need to develop sustainable ways in which to approach core compliance and risk management requirements from the start. In this session, our panel of experts will consider the ways in which Virtual Assets innovators have addressed these issues so far – successfully and otherwise – and seek to glean learning points for how Virtual Assets firms can ‘bake-in’ good practice, and develop sustainable FinCrime frameworks as an ingredient of long-term success.

Host:

• David Rowe-Francis, Founder, Praxis Compliance Consultants

Panellists:

Araba Eshun, Head of Compliance & MLRO, UK, Gemini Europe Limited

Caitlin Barnett, Director of Regulations and Compliance, Chainalysis                                                

11:20 am
The Key to FinCrime? Encryption, Privacy Enhancing Technologies and the data-sharing challenge

A common refrain amongst FinCrime professionals is that it would be easier to take on the criminals if they were more readily able to share sensitive information between organisations. Whereas criminals have no barriers to worry about in this regard, those tasked with detecting and disrupting them have to follow closely the requirements of data and privacy law, which have often proved prohibitive.

For some time, the problem has been without a potential solution. However, over recent years, the development of advanced encryption techniques, often described as ‘Privacy Enhancing Technologies’ (PETs), have opened up new opportunities for smart data sharing. According to their proponents, PETs can help institutions combine and analyse sensitive data that remains can encrypted throughout – effectively ‘sharing’ without sharing.

The potential implications for financial intelligence partnerships are significant and have thus become a major topic of interest amongst FinCrime professionals. In this session, our experts will explore the promise of PETs: from the potential FinCrime ‘use cases’, the evidence of value and workability, to the practical challenges – from the technological to the regulatory – they might also bring.

Host:

Seán Doyle, Lead, Cybersecurity and Anti-Financial Crime, World Economic Forum

 
Panellists:

Rina Shainski, Co-founder and Chairwoman, Duality Technologies

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research

10:30 am
From Siloes to Systemic Solutions: FinCrime Utilities - Long term solutions?

FinCrime professionals often argue that one of the major challenges they face is the fragmentation of the anti-FinCrime effort: not only between the public and private sectors, but between firms themselves. With each individual business seeking to identify high-risk clients and suspicious activities through their own resources alone, it can be relatively simple for sophisticated financial criminals to work around the system. One idea often discussed has been that of ‘utilities’: institutions pooling their resources and working together to undertake their FinCrime obligations jointly. The most common experiments so far have been with KYC utilities in Asia-Pacific, Africa and Europe. Separately, a group of five major banks in the Netherlands has also started building the world’s first Transaction Monitoring utility.

These kinds of projects - combining data or taking a systemic, network view - should in theory improve the industry’s ability to understand and tackle common risks. However, so far, this has not been fully demonstrated, and utilities have also generated substantial practical issues of implementation. Some of these have been unique to the specific requirements of the project at hand, whether KYC or monitoring, while others appear to be more common. Integrating the data from multiple diverse institutions has proved a technical headache for some in the KYC space already, and in a world where personal data privacy is increasingly privileged, data-pooling has faced major challenges from developments such as the EU’s General Data Protection Regulation (GDPR).  Surveying this complex landscape, the panel will assess the potential value that utilities can bring to different aspects of the fight against FinCrime, and the balance between risk and reward that might come with such ambitious collaborations.

Host:

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research    


Panellists:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Helène Erftemeijer, KYC Lead, ING

Che Sidanius, Global Head of Financial Crime and Industry Affairs, Refinitiv

Lora von Ploetz, Director/Head of Global Financial Crime Unit, Commerzbank AG                                  

4:10 pm
Pushing for the RegTech Revolution Removing the barriers to adoption in FinCrime

In a recent report, the City of London Corporation has argued that the financial services sector needs to leverage new regulatory technologies (RegTech) to meet their obligations and fight financial crime. The report follows a succession of other statements from leading regulators in the US, Europe and Asia-Pacific, all making similar points.

However, as the City of London also notes, the take up of RegTech – though comparatively better in the FinCrime space than other areas – is still limited overall. A lack of practical rather than rhetorical regulator support has been proposed as one cause for this, and there are likely to be other barriers too. Some of the most innovative RegTechs are relatively small or young firms that find it difficult to satisfy the risk requirements of large and mature financial institutions. Even when the solution on offer is a good fit, it can sometimes be impractical for either side to work together.

In this session, the panellists will provide a pragmatic view on the state of RegTech adoption in the industry and seek to get to the root causes of its currently slow pace, looking at regulatory, commercial as well as technological points of friction. The panel will also look at ways the current initiatives to support RegTech, such as regulatory sandboxes and ‘Tech Sprints’, might be enhanced and expanded in order to ensure the sector meets its full potential in the future.

Host:

Christopher Woolard CBE, Partner, EMEIA Financial Services Consulting & Chair, EY Global Regulatory Network, EY LLP

Panellists:

Dr Sian Lewin, Co-Founder and Head of Client Delivery, RegTech Associates

Francesca Hopwood Road, Head of RegTech & Advanced Analytics, FCA

3:20 pm
Beyond the Banking Bubble Leveraging technology lessons from other industries

In the last few years, financial services providers and Regulatory Technology (RegTech) firms have talked a great deal about the deployment of new data-driven technologies, usually with a focus on automation and supervised machine learning to core compliance tasks such as sanctions screening and transaction monitoring. However, in spite of the competitiveness between RegTechs, platforms have sometimes been less advanced than they might seem, given their need to pass tight regulatory validation requirements.

In contrast, other industries and sectors are finding ambitious ways in which to leverage new technologies with fewer constraints. In healthcare, for example, providers are increasingly using more advanced supervised and unsupervised machine learning models, allowing Artificial Intelligence (AI) to play greater roles in decision-making in diagnosis and prescription. If a ‘trust but verify’ approach can be applied to human health, there are questions to ask about why we cannot take the same stance when it comes to financial crime risk.

In this session, our panel of experts will therefore take us beyond the boundaries of the FinCrime world, to explore the ways in which new technologies are being applied to other industries and sectors; consider how their techniques might be translated into the fight against financial crime; and review the ways in which FinCrime regulators too could learn from their counterparts in other sectors.

2:30 pm
United We Stand The potential for integrated FinCrime teams and controls

The problem of fragmentation affects the world of FinCrime in many ways. Within compliance and risk management functions, the past isolation of AML, fraud and sanctions teams has led to key risks falling between the institutional gaps – a problem exacerbated when the teams use different platforms and data streams. FinCrime measures as conventionally applied also have temporal as well as organisational gaps, with retrospective monitoring leading to delays in suspicious activity reporting, and slow KYC refresh cycles meaning that customer risk profiles remain woefully out of date.

Many businesses are thus now seeking ways to make their FinCrime frameworks more responsive to real-time demands. Some larger financial institutions have restructured their FinCrime ‘estates’ to bring previously separate teams together and deployed new technologies to create a more integrated approach: concepts such as ‘seamless AML’ and ‘perpetual KYC’ have now started moving from idea to reality.

In this panel, our experts will investigate the problems of fragmentation and delay in traditional FinCrime frameworks and explore the progress that innovators in the financial services sector have made so far in creating a more coherent response, especially with new technologies. They will also consider where such changes are leading, and whether it is realistic to expect we can make our own frameworks as agile and coherent as those of the financial criminals themselves.

1:00 pm
Above the Law? The challenge of bringing financial criminals to justice

The social restrictions of the COVID-19 pandemic have been a major impediment to financial criminals, who rely on easy access to the financial system to move dirty money. Law enforcement agencies – seeking to make the best of a difficult situation – have been able to take advantage, seizing large amounts of illicit cash that would otherwise have been laundered through the system, or smuggled to high-risk jurisdictions.

Nonetheless, these recent successes - often highlighted in the media - should not detract from the underlying reality that all law enforcement agencies are struggling to reduce the scale and scope of FinCrime. According to most reliable global estimates, no more than 1-2% of illicit funds are ever retrieved by the authorities – an astonishingly low figure.

Our panel of experts will probe into the reasons behind this apparent failure to retrieve funds and bring financial criminals to justice, exploring systemic weaknesses and vulnerabilities that generate such poor operational outcomes. At the same time, the panel will also explore the potential of new initiatives, such as Unexplained Wealth Orders (UWOs), to rebalance the playing field, and consider new ways in which the private sector could support the authorities’ campaign against financial criminals.

Host:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Panellists:

Aidan Larkin, CEO, Asset Reality

Carmel King, Director, Insolvency and Asset Recovery, Grant Thornton UK LLP

Sarah Hargreaves, ACI, ACE, Director of Training - International, Exterro      

12:10 pm
The Last Lines of Defence Strengthening the professions’ fight against FinCrime

Most public attention on the private sector’s efforts against FinCrime is devoted to the role of financial institutions, and in particular, banks. This is quite logical, given the centrality of their roles as the gatekeepers of the financial system, and the parts they have unwittingly played in moving illicit funds around the global economy.

However, FinCrime does not touch the financial sector alone, and the vulnerability of professions such as lawyers and accountants to becoming the tools of financial criminality has become more apparent in recent years. Estate agents’ services have also been abused by criminals seeking to ‘integrate’ illicit funds into the legitimate economy – indeed, the role illicit cash has played in property price booms has been widely reported. At the same time, the professions are still relatively minor reporters of suspicious activities to the authorities. Despite the warning signs, it does not appear that the professions have yet taken the issue as seriously as they should.

In this panel, our experts examine how financial criminals have made use of a variety of professional services to protect and enjoy their illicit funds, and ask why, so far, many firms in those sectors have failed to take FinCrime seriously. The panel will also consider ways in which regulators can encourage a more proactive approach, and how the wider private sector community can bring the professions into the fold.

Host:

Matthew Redhead, Associate Fellow, RUSI.


Panellists:

Dr Anna Bradshaw, Partner, Peters & Peters Solicitors LLP.
Dr Katie Benson, Lecturer in Criminology, Lancaster University.                                                    

11:20 am
Cultural Capital Can we achieve a positive FinCrime ‘compliance culture’?

For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.

10:30 am
Moving the Needle - Defining, measuring, and improving FinCrime effectiveness

Many key players in the FinCrime world have been seeking to define the term ‘effectiveness’. Following the lead of the global standard setters, the Financial Action Task Force (FATF), most regulators have sought to assess the issue through subjective evaluations of ‘how well’ businesses meet their compliance obligations. Recently, the US federal government’s Financial Crimes Enforcement Network (FinCEN) has sought to take a more measurable approach, suggesting that an ‘effective’ FinCrime programme delivers ‘useful’ Suspicious Activity Reports (SARs) – in other words, financial intelligence that materially helps law enforcement investigations.

But despite such attempts to take a granular and concrete approach, the meaning of the term ‘effectiveness’ is still ambiguous for stakeholders in both the public and private sectors and is often re-interpreted to mean measuring what is easy – especially outputs and efficiency – rather what matters – outcomes and impact. In this panel therefore, we bring together a number of leading FinCrime practitioners to scrutinise what the term effectiveness can – and more importantly should – mean in the for the stakeholders in the FinCrime world, and explore pragmatic and practical ways in which all stakeholders can help ‘move the needle’ in a positive direction

Host:
John Cusack, Chair, Global Coalition to Fight Financial Crime
Panellists:
Geraldine Lawlor, Global Lead Partner for Financial Crime, KPMG LLP
Dr Ronald Pol, Director and Principal, TeamFactors.com and AMLassurance.com
Gemma Rogers, Co-founder, FINTRAIL
Daniel Thelesklaf, Director, Finance Against Slavery and Trafficking, UN University – Centre for Policy Research
Vishal Marria, CEO, Quantexa
                                   
8:00 am
A Talk on the Wild Side - A conversation on the Wildlife-FinCrime nexus with John Scanlon

The potential link between the illegal wildlife trade and the spread of COVID-19 has focused attention once again on the trafficking and exploitation of wild animals, as well as plants. Exotic animals can often bring incredible prices in illicit markets, and according to the UN, wildlife crime has become a “significant and specialised” form of transnational crime in its own right.

Australian lawyer John Scanlon has been one of the leading global voices against this trade, and currently holds three major positions with campaigning organisations: CEO of the Elephant Protection Initiative (EPI) Foundation, Chair of the Global Alliance to End Wildlife Crime, and Chair of the UK Government's Illegal Wildlife Trade Challenge Fund. He has also served as the Secretary-General of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) for nearly a decade between 2010-2018.

There are few campaigners as intimately aware of the realities of the illegal wildlife trade, and in this session, John will share his experiences of the fight, as well as his perspectives on how to go about tackling this pernicious problem more effectively. Looking to a dedicated and coordinated global effort, tougher regulation and enforcement, he argues that the illegal wildlife trade is “not a poor man’s crime”, and that governments need to focus on following dirty money in exactly the same way as with other major forms of serious organised criminality.

Interview with John E Scanlon AO, Chair, Global Initiative to End Wildlife Crime

Wednesday 23rd June

8:00 am
A Talk on the Wild Side - A conversation on the Wildlife-FinCrime nexus with John Scanlon

The potential link between the illegal wildlife trade and the spread of COVID-19 has focused attention once again on the trafficking and exploitation of wild animals, as well as plants. Exotic animals can often bring incredible prices in illicit markets, and according to the UN, wildlife crime has become a “significant and specialised” form of transnational crime in its own right.

Australian lawyer John Scanlon has been one of the leading global voices against this trade, and currently holds three major positions with campaigning organisations: CEO of the Elephant Protection Initiative (EPI) Foundation, Chair of the Global Alliance to End Wildlife Crime, and Chair of the UK Government's Illegal Wildlife Trade Challenge Fund. He has also served as the Secretary-General of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) for nearly a decade between 2010-2018.

There are few campaigners as intimately aware of the realities of the illegal wildlife trade, and in this session, John will share his experiences of the fight, as well as his perspectives on how to go about tackling this pernicious problem more effectively. Looking to a dedicated and coordinated global effort, tougher regulation and enforcement, he argues that the illegal wildlife trade is “not a poor man’s crime”, and that governments need to focus on following dirty money in exactly the same way as with other major forms of serious organised criminality.

Interview with John E Scanlon AO, Chair, Global Initiative to End Wildlife Crime

9:00 am
Complying with Diversity Building an inclusive FinCrime profession

Critics often complain that the FinCrime compliance profession is something of a closed-shop for white, middle-class men who have worked for decades in the financial services sector, and dominate the top tiers of senior management in the field. This kind of characterisation is not wholly fair, of course. Increasing amounts of women are developing sustainable and successful careers in the industry, as too are those coming from a Black, Asian or Minority Ethnic (BAME) background. But most in the industry will admit that there is still a distance to go.

The industry also continues to be siloed in other ways, with financial services compliance still seen by many in the field as a ‘career for life’ that requires little input from other professional perspectives. This preconception has been challenged over the last decade too, by an influx of staff from public sector backgrounds such as law enforcement and intelligence, and increasing numbers of technically savvy individuals who work with data and advanced platforms. The rise of fintech has also played a role, bringing a wider range of young, talented individuals who want to challenge the ‘group think’ of pre-existing FinCrime approaches into the field.

In this session, our panellists will discuss the practical value that a diversity of skills and experience can bring to the execution of compliance and risk management, and consider the challenges that come with building and sustaining diverse teams. The panel will also identify good practice from both within and beyond the sector, to help firms get the best out of their people, whatever their backgrounds.

10:30 am
Moving the Needle - Defining, measuring, and improving FinCrime effectiveness

Many key players in the FinCrime world have been seeking to define the term ‘effectiveness’. Following the lead of the global standard setters, the Financial Action Task Force (FATF), most regulators have sought to assess the issue through subjective evaluations of ‘how well’ businesses meet their compliance obligations. Recently, the US federal government’s Financial Crimes Enforcement Network (FinCEN) has sought to take a more measurable approach, suggesting that an ‘effective’ FinCrime programme delivers ‘useful’ Suspicious Activity Reports (SARs) – in other words, financial intelligence that materially helps law enforcement investigations.

But despite such attempts to take a granular and concrete approach, the meaning of the term ‘effectiveness’ is still ambiguous for stakeholders in both the public and private sectors and is often re-interpreted to mean measuring what is easy – especially outputs and efficiency – rather what matters – outcomes and impact. In this panel therefore, we bring together a number of leading FinCrime practitioners to scrutinise what the term effectiveness can – and more importantly should – mean in the for the stakeholders in the FinCrime world, and explore pragmatic and practical ways in which all stakeholders can help ‘move the needle’ in a positive direction

Host:
John Cusack, Chair, Global Coalition to Fight Financial Crime
Panellists:
Geraldine Lawlor, Global Lead Partner for Financial Crime, KPMG LLP
Dr Ronald Pol, Director and Principal, TeamFactors.com and AMLassurance.com
Gemma Rogers, Co-founder, FINTRAIL
Daniel Thelesklaf, Director, Finance Against Slavery and Trafficking, UN University – Centre for Policy Research
Vishal Marria, CEO, Quantexa
                                   
11:20 am
Cultural Capital Can we achieve a positive FinCrime ‘compliance culture’?

For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.

12:10 pm
The Last Lines of Defence Strengthening the professions’ fight against FinCrime

Most public attention on the private sector’s efforts against FinCrime is devoted to the role of financial institutions, and in particular, banks. This is quite logical, given the centrality of their roles as the gatekeepers of the financial system, and the parts they have unwittingly played in moving illicit funds around the global economy.

However, FinCrime does not touch the financial sector alone, and the vulnerability of professions such as lawyers and accountants to becoming the tools of financial criminality has become more apparent in recent years. Estate agents’ services have also been abused by criminals seeking to ‘integrate’ illicit funds into the legitimate economy – indeed, the role illicit cash has played in property price booms has been widely reported. At the same time, the professions are still relatively minor reporters of suspicious activities to the authorities. Despite the warning signs, it does not appear that the professions have yet taken the issue as seriously as they should.

In this panel, our experts examine how financial criminals have made use of a variety of professional services to protect and enjoy their illicit funds, and ask why, so far, many firms in those sectors have failed to take FinCrime seriously. The panel will also consider ways in which regulators can encourage a more proactive approach, and how the wider private sector community can bring the professions into the fold.

Host:

Matthew Redhead, Associate Fellow, RUSI.


Panellists:

Dr Anna Bradshaw, Partner, Peters & Peters Solicitors LLP.
Dr Katie Benson, Lecturer in Criminology, Lancaster University.                                                    

1:00 pm
Above the Law? The challenge of bringing financial criminals to justice

The social restrictions of the COVID-19 pandemic have been a major impediment to financial criminals, who rely on easy access to the financial system to move dirty money. Law enforcement agencies – seeking to make the best of a difficult situation – have been able to take advantage, seizing large amounts of illicit cash that would otherwise have been laundered through the system, or smuggled to high-risk jurisdictions.

Nonetheless, these recent successes - often highlighted in the media - should not detract from the underlying reality that all law enforcement agencies are struggling to reduce the scale and scope of FinCrime. According to most reliable global estimates, no more than 1-2% of illicit funds are ever retrieved by the authorities – an astonishingly low figure.

Our panel of experts will probe into the reasons behind this apparent failure to retrieve funds and bring financial criminals to justice, exploring systemic weaknesses and vulnerabilities that generate such poor operational outcomes. At the same time, the panel will also explore the potential of new initiatives, such as Unexplained Wealth Orders (UWOs), to rebalance the playing field, and consider new ways in which the private sector could support the authorities’ campaign against financial criminals.

Host:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Panellists:

Aidan Larkin, CEO, Asset Reality

Carmel King, Director, Insolvency and Asset Recovery, Grant Thornton UK LLP

Sarah Hargreaves, ACI, ACE, Director of Training - International, Exterro      

2:30 pm
United We Stand The potential for integrated FinCrime teams and controls

The problem of fragmentation affects the world of FinCrime in many ways. Within compliance and risk management functions, the past isolation of AML, fraud and sanctions teams has led to key risks falling between the institutional gaps – a problem exacerbated when the teams use different platforms and data streams. FinCrime measures as conventionally applied also have temporal as well as organisational gaps, with retrospective monitoring leading to delays in suspicious activity reporting, and slow KYC refresh cycles meaning that customer risk profiles remain woefully out of date.

Many businesses are thus now seeking ways to make their FinCrime frameworks more responsive to real-time demands. Some larger financial institutions have restructured their FinCrime ‘estates’ to bring previously separate teams together and deployed new technologies to create a more integrated approach: concepts such as ‘seamless AML’ and ‘perpetual KYC’ have now started moving from idea to reality.

In this panel, our experts will investigate the problems of fragmentation and delay in traditional FinCrime frameworks and explore the progress that innovators in the financial services sector have made so far in creating a more coherent response, especially with new technologies. They will also consider where such changes are leading, and whether it is realistic to expect we can make our own frameworks as agile and coherent as those of the financial criminals themselves.

3:20 pm
Beyond the Banking Bubble Leveraging technology lessons from other industries

In the last few years, financial services providers and Regulatory Technology (RegTech) firms have talked a great deal about the deployment of new data-driven technologies, usually with a focus on automation and supervised machine learning to core compliance tasks such as sanctions screening and transaction monitoring. However, in spite of the competitiveness between RegTechs, platforms have sometimes been less advanced than they might seem, given their need to pass tight regulatory validation requirements.

In contrast, other industries and sectors are finding ambitious ways in which to leverage new technologies with fewer constraints. In healthcare, for example, providers are increasingly using more advanced supervised and unsupervised machine learning models, allowing Artificial Intelligence (AI) to play greater roles in decision-making in diagnosis and prescription. If a ‘trust but verify’ approach can be applied to human health, there are questions to ask about why we cannot take the same stance when it comes to financial crime risk.

In this session, our panel of experts will therefore take us beyond the boundaries of the FinCrime world, to explore the ways in which new technologies are being applied to other industries and sectors; consider how their techniques might be translated into the fight against financial crime; and review the ways in which FinCrime regulators too could learn from their counterparts in other sectors.

4:10 pm
Pushing for the RegTech Revolution Removing the barriers to adoption in FinCrime

In a recent report, the City of London Corporation has argued that the financial services sector needs to leverage new regulatory technologies (RegTech) to meet their obligations and fight financial crime. The report follows a succession of other statements from leading regulators in the US, Europe and Asia-Pacific, all making similar points.

However, as the City of London also notes, the take up of RegTech – though comparatively better in the FinCrime space than other areas – is still limited overall. A lack of practical rather than rhetorical regulator support has been proposed as one cause for this, and there are likely to be other barriers too. Some of the most innovative RegTechs are relatively small or young firms that find it difficult to satisfy the risk requirements of large and mature financial institutions. Even when the solution on offer is a good fit, it can sometimes be impractical for either side to work together.

In this session, the panellists will provide a pragmatic view on the state of RegTech adoption in the industry and seek to get to the root causes of its currently slow pace, looking at regulatory, commercial as well as technological points of friction. The panel will also look at ways the current initiatives to support RegTech, such as regulatory sandboxes and ‘Tech Sprints’, might be enhanced and expanded in order to ensure the sector meets its full potential in the future.

Host:

Christopher Woolard CBE, Partner, EMEIA Financial Services Consulting & Chair, EY Global Regulatory Network, EY LLP

Panellists:

Dr Sian Lewin, Co-Founder and Head of Client Delivery, RegTech Associates

Francesca Hopwood Road, Head of RegTech & Advanced Analytics, FCA

8:15 am
FinCrime’s Pivotal Moment - A conversation with Burkhard Mühl, Head of the European Financial & Economic Crime Centre, Europol

The 2021 Serious and Organised Crime Threat Assessment (SOCTA) from Europol, the EU’s policing agency, made for sombre reading. According to the report, organised criminality in Europe is more complex and fluid than ever before, with different criminal gangs working together ‘as needed’, on the basis of mutual self-interest. Unlike the old-fashioned ‘Godfather’ model of organised criminality imagined in films and TV, modern master criminals are now as agile and collaborative as the entrepreneurs of the technology sector. Laundering the funds generated by these illicit criminal activities has become as equally sophisticated as the predicate crimes themselves, with professionalised networks, often operating through legitimate business structures, insulated from effective disruption by systemic corruption of individuals in the public sector, financial institutions and professions. As a consequence, the management of illicit finance has become deeply rooted in societies and economies, with its scale and complexity probably significantly greater than previously thought.

In this interview, we explore these issues in depth with Burkhard Mühl, since December 2020 the Head of the newly created European Financial & Economic Crime Centre (EFECC) at Europol. Herr Mühl – a 35-year veteran of Austrian and European law enforcement – believes that serious and organised crime and illicit finance are now major challenges for the EU, and therefore need to be addressed not only with new vigour, but a more strategic approach that targets the ‘high value’ kingpins at the centres of the networks. He also contends that to put organised criminals and money launderers on the defensive, law enforcement agencies and their partners in the private sector will need to learn lessons from their opponents’ success – by becoming ‘masters of collaboration’ in their own right.

Interview with Burkhard Mühl, Head of European Financial & Economic Crime Centre, Europol        

9:00 am
Tackling the Dark Underbelly of the Illegal Wildlife Trade A presentation by Araluen Schunmann, Director, Pangolin Crisis Fund

Anti-financial crime practitioners know that the illicit trade in wildlife has become a major source of illicit funds in the global criminal economy. But what do practitioners know about how the criminals conduct their business? In comparison to illicit activities such as drugs and human trafficking, the modus operandi of illicit wildlife traders is much less well-known. There are good reasons for this, of course, given the relative immaturity of the international effort to tackle the problem. But even so, we are learning – slowly – about how the wildlife traffickers operate.

In this presentation, Araluen Schunmann, Director of the Pangolin Crisis Fund for the Wildlife Conservation Network (WCN), will explore how the trade works, providing insights into the international supply chain for wildlife, the demand and supply that drive the illegal market, and the important role that corruption plays in enabling the trade. She will also explore how law enforcement agencies and NGOs seek to investigate these crimes, while providing a frank assessment of the roadblocks they face. What good can a SAR do against a sophisticated international network, and what prospects are there for the investigation and prosecution of traffickers at the top of the criminal organisations, rather than lower-level operatives who facilitate the trade on a day-to-day basis? Providing a balanced view of where we are in the fight, the presentation will not only explore emerging strategies for tackling the trade, but also address what else will need to change for the international community to have a significant impact.

Presented by Araluen Schunmann, Director of the Pangolin Crisis Fund, ‎Wildlife Conservation Network

9:45 am
Fighting Kleptopia -A conversation with Tom Burgis, author of ‘Kleptopia: How Dirty Money is Conquering the World’.

Even a decade ago, the emergence of kleptocracy – a political system where leaders use their positions of power to enrich themselves – was seen by those living in ‘developed’ states as being a marginal risk that affected only poor or undemocratic societies. However, as we have learned since then, no society – however well-established – is immune from the lure of financial and political corruption.

One of the leading journalists chronicling the progress of kleptocracy across the world is Tom Burgis, an award-winning reporter and a long-standing member of the Financial Times’ investigations team. In his most recent book, Kleptopia, published in 2020, Burgis exposes how seemingly disparate events, such as a massacre on the Kazakh steppe or a stolen election in Zimbabwe, can be linked to a hidden web of connections that touches centres of power not only in Beijing and the Kremlin, but also the City of London and, ultimately, the White House.

In this session, Burgis will discuss the inner workings of this growing global network of kleptocratic elites, and the efforts of quiet heroes seeking to highlight this problem, such as the compliance officer-turned-whistleblower Nigel Wilkins, who features in the book. Burgis also will explore how half-hearted government and private sector initiatives have failed to challenge the problems of corruption and illicit finance so far, and consider more effective ways to take the fight to the kleptocrats, now.  

Interview with Tom Burgis, Investigations correspondent, Financial Times

10:30 am
From Siloes to Systemic Solutions: FinCrime Utilities - Long term solutions?

FinCrime professionals often argue that one of the major challenges they face is the fragmentation of the anti-FinCrime effort: not only between the public and private sectors, but between firms themselves. With each individual business seeking to identify high-risk clients and suspicious activities through their own resources alone, it can be relatively simple for sophisticated financial criminals to work around the system. One idea often discussed has been that of ‘utilities’: institutions pooling their resources and working together to undertake their FinCrime obligations jointly. The most common experiments so far have been with KYC utilities in Asia-Pacific, Africa and Europe. Separately, a group of five major banks in the Netherlands has also started building the world’s first Transaction Monitoring utility.

These kinds of projects - combining data or taking a systemic, network view - should in theory improve the industry’s ability to understand and tackle common risks. However, so far, this has not been fully demonstrated, and utilities have also generated substantial practical issues of implementation. Some of these have been unique to the specific requirements of the project at hand, whether KYC or monitoring, while others appear to be more common. Integrating the data from multiple diverse institutions has proved a technical headache for some in the KYC space already, and in a world where personal data privacy is increasingly privileged, data-pooling has faced major challenges from developments such as the EU’s General Data Protection Regulation (GDPR).  Surveying this complex landscape, the panel will assess the potential value that utilities can bring to different aspects of the fight against FinCrime, and the balance between risk and reward that might come with such ambitious collaborations.

Host:

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research    


Panellists:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Helène Erftemeijer, KYC Lead, ING

Che Sidanius, Global Head of Financial Crime and Industry Affairs, Refinitiv

Lora von Ploetz, Director/Head of Global Financial Crime Unit, Commerzbank AG                                  

11:20 am
The Key to FinCrime? Encryption, Privacy Enhancing Technologies and the data-sharing challenge

A common refrain amongst FinCrime professionals is that it would be easier to take on the criminals if they were more readily able to share sensitive information between organisations. Whereas criminals have no barriers to worry about in this regard, those tasked with detecting and disrupting them have to follow closely the requirements of data and privacy law, which have often proved prohibitive.

For some time, the problem has been without a potential solution. However, over recent years, the development of advanced encryption techniques, often described as ‘Privacy Enhancing Technologies’ (PETs), have opened up new opportunities for smart data sharing. According to their proponents, PETs can help institutions combine and analyse sensitive data that remains can encrypted throughout – effectively ‘sharing’ without sharing.

The potential implications for financial intelligence partnerships are significant and have thus become a major topic of interest amongst FinCrime professionals. In this session, our experts will explore the promise of PETs: from the potential FinCrime ‘use cases’, the evidence of value and workability, to the practical challenges – from the technological to the regulatory – they might also bring.

Host:

Seán Doyle, Lead, Cybersecurity and Anti-Financial Crime, World Economic Forum

 
Panellists:

Rina Shainski, Co-founder and Chairwoman, Duality Technologies

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research

12:50 pm
FinCrime’s Wider Responsibility- Environmental, Social and Governance Reporting in FinCrime Compliance A presentation by Michael Rasmussen

In a world increasingly concerned with nurturing sustainability, businesses now take a greater interest in the wider impacts that they have on the environments and societies in which they operate. As part of this trend, Environmental, Social and Governance (ESG) reporting has become a common feature of how businesses seek to manage and explain their approach to these issues to regulators, investors, customers and employees.

Nonetheless, despite its recent spread, ESG reporting is often not fully understood, even in compliance tems. Although the issue of environmental impact is well-known, the full gamut of social concerns that need to be covered in ESG, from privacy, modern slavery, through to inclusion and diversity – are much less appreciated, as too is the role that governance needs to play in the management of financial crime risks such as fraud, bribery and corruption. To have an effective ESG program requires that financial crime compliance teams be a critical part of the reporting strategy.

In this session, Michael Rasmussen, aka ‘The GRC Pundit’, will help participants think through the essentials of an effective ESG program, and will cover: challenges of definition and scope; the clarification of regulatory and stakeholder requirements; the role that financial crime compliance teams need to play; and strategy and processes of ESG reporting. Michael is an internationally recognised commentator and consultant on Governance, Risk and Compliance (GRC) – a term he himself coined – and has over three decades of experience in the field. A popular presenter from our March conference, we are delighted to welcome him back

Presented by Michael Rasmussen, GRC Analyst & Pundit, GRC 20/20 Research

2:00 pm
The Real Ingredients of Virtual Compliance ‘Baking-in’ FinCrime good practice from the start

For entrepreneurs in any space there is often a desire to do things ‘differently’. Indeed, that is a prime motivation: to deliver a new product to customers. It can be tempting to focus on getting this right, providing a high-quality customer experience, and stimulating growth, to the exclusion of other concerns. Although compliance, regulation and risk management do not get ignored, they can slip down the list of priorities.

This has undoubtedly been a common challenge in the Virtual Assets sector, where innovators focused on developing new types of asset, product or service have sometimes found themselves dealing with issues of financial crime compliance last - with dire commercial and sometimes legal consequences. In some recent cases, the spread of stronger global AML/CFT requirements for the industry has led firms who did not factor such matters in from the start to go out of business. In other cases, failures to meet regulatory requirements have led to fines and regulatory censure.

If the Virtual Assets sector is to continue its remarkable growth, therefore, entrepreneurs and firms in the sector will need to develop sustainable ways in which to approach core compliance and risk management requirements from the start. In this session, our panel of experts will consider the ways in which Virtual Assets innovators have addressed these issues so far – successfully and otherwise – and seek to glean learning points for how Virtual Assets firms can ‘bake-in’ good practice, and develop sustainable FinCrime frameworks as an ingredient of long-term success.

Host:

• David Rowe-Francis, Founder, Praxis Compliance Consultants

Panellists:

Araba Eshun, Head of Compliance & MLRO, UK, Gemini Europe Limited

Caitlin Barnett, Director of Regulations and Compliance, Chainalysis                                                

2:50 pm
Crypto 2.0 – New ways of performing old tricks? Exploring Crypto Typologies with Nick Furneaux

Any sufficiently new technology can seem like magic to the uninitiated, and it can become easy to assume that its abuse by criminals is equally magical and just as perplexing. It can also become a natural next step to assume that there is a particular type of ‘crime’ inherent to the new technology in question.

Rarely in recent years have new technologies been so quickly framed in this way as blockchain and cryptocurrencies. FinCrime discourse has quickly assumed that not only is cryptocurrency inherently riskier than fiat currency, but that there is a particular form of distinctive crime – ‘crypto crime’ – that is intimately linked to it.

But despite these presumptions, the truth about the criminal abuse of cryptocurrency is considerably more prosaic. ‘Crypto crimes’ are in fact just good, old-fashioned crimes, with a new ‘virtual’ twist, according to Nick Furneaux, Managing Director of CSITech and author of Investigating Cryptocurrencies. In this session, Nick will follow up his popular talk from our March conference with an exploration of the classic criminal typologies that get applied to cryptocurrencies and provide potential investors with a range of issues to consider when dealing safely in this evolving market.

Presented by Nick Furneaux, MD at CSITech and CTO at Asset Reality                                                  

3:50 pm
Off the Crypto Rollercoaster Are stable coins and centralised digital currencies 'safe' alternatives?

In the face of soaring market values for a variety of cryptocurrencies, public authorities and established financial institutions across the world have been forced to start considering the implications of these assets’ wider usage. Cryptocurrencies are no longer seen to be a ‘fringe’ interest, or of little relevance to the wider economy.

Nonetheless, concerns continue about the perceived risks of market failure and abuse that come with the assets. Organisations in the public and private sectors are both trying to clarify their approaches to the issue. Some are rejecting crypto outright, while others are choosing to ride the rollercoaster. But between the extremes, others have been seeking to develop crypto in a more ‘risk friendly’ way. Private stablecoins – cryptocurrencies linked to the value of more tangible assets – are one proposed solution – while fully digitalised versions of pre-existing fiat currencies are another.

In this panel, our experts will explore the growing diversity of virtual and digital currencies, the likely future trends, and the growing role that governments and ‘big technology’ firms are seeking to play in the space. They will also ask whether these alternatives can really have the same market appeal as pure ‘crypto’ - without the potential risks.

4:40 pm
Scanning the Virtual Horizon The next steps for global Virtual Asset regulation

In March 2021, the Financial Action Task Force (FATF), the international standard setter for FinCrime, issued new guidelines on a risk-based approach to Virtual Assets and Virtual Asset Service Providers. Coming less than two years after its first guidelines on the area, the document has sought to clarify uncertainties, fill gaps, and update the rules in light of the fast-growing scope of the sector. Overall, the new guidelines have pointed towards a more stringent approach than before, with a widened definition of Virtual Assets, and additional references to stable coins, Decentralised Finance (DeFi) and Non-Fungible Tokens (NFT). Some FATF members have already starting taking a tougher line on the question, and those that have not are likely to follow suit in the near future.

But is this the right approach for Virtual Assets, or even the only approach? Is it possible to continue to apply a framework designed for fiat currencies to the virtual space? Or will a bespoke approach be required? In this panel, our speakers will review the current ‘state of play’ in the regulation of Virtual Assets, the philosophy behind regulators’ policies, and assess where regulators might go next. The panel will explore whether other regulatory models or bespoke alternatives might be applied to better effect, and the potential scope for regulatory innovation.

5:30 pm
Scams: Fuelling the Crypto Fire A presentation by Scott Johnson, Chainanalysis

In its 2021 Crypto Crime Report, Chainanalysis, a leading blockchain analysis company, found that scams – ranging from Darknet market abuse, extortion, phishing to Ponzi schemes – continue to be the highest-grossing forms of cryptocurrency-based crime, bringing in around $2.7 billion to criminals. Last year, scam-type crimes – especially fake investment schemes – were also affecting more individuals than ever before, with the number of separate payments to scam addresses rising from just over 5 to 7.3 million – a potential rise in victim numbers of more than 48%. Scams have always been big business for serious organised criminality, and the expansion of cryptocurrency usage has provided new options not only to make money, but to launder it too.In this session, we will be hearing from Scott Johnston, Head of Public Sector Outreach (EMEA) at Chainanalysis, the company behind the report, who will provide a realistic and evidence-driven overview of where we are with crypto-linked scamming. Scott – a former UK police officer with 18 years’ experience investigating serious organised crime, money laundering and emerging crypto threats – will help participants understand what the headline figures mean in practice, learning about 2020’s most significant scam-related cases and the likely trends in the crypto crime ecosystem in 2021. Scott will also explore how we can start to take ‘the fuel off the fire’, using blockchain analysis as a way to profile and track down scammers and identify new leads.

Presented by Scott Johnston, Head of Public Sector Operations, EMEA, Chainalysis                                                  

Wednesday 23rd June

8:00 am
A Talk on the Wild Side - A conversation on the Wildlife-FinCrime nexus with John Scanlon

The potential link between the illegal wildlife trade and the spread of COVID-19 has focused attention once again on the trafficking and exploitation of wild animals, as well as plants. Exotic animals can often bring incredible prices in illicit markets, and according to the UN, wildlife crime has become a “significant and specialised” form of transnational crime in its own right.

Australian lawyer John Scanlon has been one of the leading global voices against this trade, and currently holds three major positions with campaigning organisations: CEO of the Elephant Protection Initiative (EPI) Foundation, Chair of the Global Alliance to End Wildlife Crime, and Chair of the UK Government's Illegal Wildlife Trade Challenge Fund. He has also served as the Secretary-General of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) for nearly a decade between 2010-2018.

There are few campaigners as intimately aware of the realities of the illegal wildlife trade, and in this session, John will share his experiences of the fight, as well as his perspectives on how to go about tackling this pernicious problem more effectively. Looking to a dedicated and coordinated global effort, tougher regulation and enforcement, he argues that the illegal wildlife trade is “not a poor man’s crime”, and that governments need to focus on following dirty money in exactly the same way as with other major forms of serious organised criminality.

Interview with John E Scanlon AO, Chair, Global Initiative to End Wildlife Crime

9:00 am
Complying with Diversity Building an inclusive FinCrime profession

Critics often complain that the FinCrime compliance profession is something of a closed-shop for white, middle-class men who have worked for decades in the financial services sector, and dominate the top tiers of senior management in the field. This kind of characterisation is not wholly fair, of course. Increasing amounts of women are developing sustainable and successful careers in the industry, as too are those coming from a Black, Asian or Minority Ethnic (BAME) background. But most in the industry will admit that there is still a distance to go.

The industry also continues to be siloed in other ways, with financial services compliance still seen by many in the field as a ‘career for life’ that requires little input from other professional perspectives. This preconception has been challenged over the last decade too, by an influx of staff from public sector backgrounds such as law enforcement and intelligence, and increasing numbers of technically savvy individuals who work with data and advanced platforms. The rise of fintech has also played a role, bringing a wider range of young, talented individuals who want to challenge the ‘group think’ of pre-existing FinCrime approaches into the field.

In this session, our panellists will discuss the practical value that a diversity of skills and experience can bring to the execution of compliance and risk management, and consider the challenges that come with building and sustaining diverse teams. The panel will also identify good practice from both within and beyond the sector, to help firms get the best out of their people, whatever their backgrounds.

10:30 am
Moving the Needle - Defining, measuring, and improving FinCrime effectiveness

Many key players in the FinCrime world have been seeking to define the term ‘effectiveness’. Following the lead of the global standard setters, the Financial Action Task Force (FATF), most regulators have sought to assess the issue through subjective evaluations of ‘how well’ businesses meet their compliance obligations. Recently, the US federal government’s Financial Crimes Enforcement Network (FinCEN) has sought to take a more measurable approach, suggesting that an ‘effective’ FinCrime programme delivers ‘useful’ Suspicious Activity Reports (SARs) – in other words, financial intelligence that materially helps law enforcement investigations.

But despite such attempts to take a granular and concrete approach, the meaning of the term ‘effectiveness’ is still ambiguous for stakeholders in both the public and private sectors and is often re-interpreted to mean measuring what is easy – especially outputs and efficiency – rather what matters – outcomes and impact. In this panel therefore, we bring together a number of leading FinCrime practitioners to scrutinise what the term effectiveness can – and more importantly should – mean in the for the stakeholders in the FinCrime world, and explore pragmatic and practical ways in which all stakeholders can help ‘move the needle’ in a positive direction

Host:
John Cusack, Chair, Global Coalition to Fight Financial Crime
Panellists:
Geraldine Lawlor, Global Lead Partner for Financial Crime, KPMG LLP
Dr Ronald Pol, Director and Principal, TeamFactors.com and AMLassurance.com
Gemma Rogers, Co-founder, FINTRAIL
Daniel Thelesklaf, Director, Finance Against Slavery and Trafficking, UN University – Centre for Policy Research
Vishal Marria, CEO, Quantexa
                                   
11:20 am
Cultural Capital Can we achieve a positive FinCrime ‘compliance culture’?

For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.

12:10 pm
The Last Lines of Defence Strengthening the professions’ fight against FinCrime

Most public attention on the private sector’s efforts against FinCrime is devoted to the role of financial institutions, and in particular, banks. This is quite logical, given the centrality of their roles as the gatekeepers of the financial system, and the parts they have unwittingly played in moving illicit funds around the global economy.

However, FinCrime does not touch the financial sector alone, and the vulnerability of professions such as lawyers and accountants to becoming the tools of financial criminality has become more apparent in recent years. Estate agents’ services have also been abused by criminals seeking to ‘integrate’ illicit funds into the legitimate economy – indeed, the role illicit cash has played in property price booms has been widely reported. At the same time, the professions are still relatively minor reporters of suspicious activities to the authorities. Despite the warning signs, it does not appear that the professions have yet taken the issue as seriously as they should.

In this panel, our experts examine how financial criminals have made use of a variety of professional services to protect and enjoy their illicit funds, and ask why, so far, many firms in those sectors have failed to take FinCrime seriously. The panel will also consider ways in which regulators can encourage a more proactive approach, and how the wider private sector community can bring the professions into the fold.

Host:

Matthew Redhead, Associate Fellow, RUSI.


Panellists:

Dr Anna Bradshaw, Partner, Peters & Peters Solicitors LLP.
Dr Katie Benson, Lecturer in Criminology, Lancaster University.                                                    

1:00 pm
Above the Law? The challenge of bringing financial criminals to justice

The social restrictions of the COVID-19 pandemic have been a major impediment to financial criminals, who rely on easy access to the financial system to move dirty money. Law enforcement agencies – seeking to make the best of a difficult situation – have been able to take advantage, seizing large amounts of illicit cash that would otherwise have been laundered through the system, or smuggled to high-risk jurisdictions.

Nonetheless, these recent successes - often highlighted in the media - should not detract from the underlying reality that all law enforcement agencies are struggling to reduce the scale and scope of FinCrime. According to most reliable global estimates, no more than 1-2% of illicit funds are ever retrieved by the authorities – an astonishingly low figure.

Our panel of experts will probe into the reasons behind this apparent failure to retrieve funds and bring financial criminals to justice, exploring systemic weaknesses and vulnerabilities that generate such poor operational outcomes. At the same time, the panel will also explore the potential of new initiatives, such as Unexplained Wealth Orders (UWOs), to rebalance the playing field, and consider new ways in which the private sector could support the authorities’ campaign against financial criminals.

Host:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Panellists:

Aidan Larkin, CEO, Asset Reality

Carmel King, Director, Insolvency and Asset Recovery, Grant Thornton UK LLP

Sarah Hargreaves, ACI, ACE, Director of Training - International, Exterro      

2:30 pm
United We Stand The potential for integrated FinCrime teams and controls

The problem of fragmentation affects the world of FinCrime in many ways. Within compliance and risk management functions, the past isolation of AML, fraud and sanctions teams has led to key risks falling between the institutional gaps – a problem exacerbated when the teams use different platforms and data streams. FinCrime measures as conventionally applied also have temporal as well as organisational gaps, with retrospective monitoring leading to delays in suspicious activity reporting, and slow KYC refresh cycles meaning that customer risk profiles remain woefully out of date.

Many businesses are thus now seeking ways to make their FinCrime frameworks more responsive to real-time demands. Some larger financial institutions have restructured their FinCrime ‘estates’ to bring previously separate teams together and deployed new technologies to create a more integrated approach: concepts such as ‘seamless AML’ and ‘perpetual KYC’ have now started moving from idea to reality.

In this panel, our experts will investigate the problems of fragmentation and delay in traditional FinCrime frameworks and explore the progress that innovators in the financial services sector have made so far in creating a more coherent response, especially with new technologies. They will also consider where such changes are leading, and whether it is realistic to expect we can make our own frameworks as agile and coherent as those of the financial criminals themselves.

3:20 pm
Beyond the Banking Bubble Leveraging technology lessons from other industries

In the last few years, financial services providers and Regulatory Technology (RegTech) firms have talked a great deal about the deployment of new data-driven technologies, usually with a focus on automation and supervised machine learning to core compliance tasks such as sanctions screening and transaction monitoring. However, in spite of the competitiveness between RegTechs, platforms have sometimes been less advanced than they might seem, given their need to pass tight regulatory validation requirements.

In contrast, other industries and sectors are finding ambitious ways in which to leverage new technologies with fewer constraints. In healthcare, for example, providers are increasingly using more advanced supervised and unsupervised machine learning models, allowing Artificial Intelligence (AI) to play greater roles in decision-making in diagnosis and prescription. If a ‘trust but verify’ approach can be applied to human health, there are questions to ask about why we cannot take the same stance when it comes to financial crime risk.

In this session, our panel of experts will therefore take us beyond the boundaries of the FinCrime world, to explore the ways in which new technologies are being applied to other industries and sectors; consider how their techniques might be translated into the fight against financial crime; and review the ways in which FinCrime regulators too could learn from their counterparts in other sectors.

4:10 pm
Pushing for the RegTech Revolution Removing the barriers to adoption in FinCrime

In a recent report, the City of London Corporation has argued that the financial services sector needs to leverage new regulatory technologies (RegTech) to meet their obligations and fight financial crime. The report follows a succession of other statements from leading regulators in the US, Europe and Asia-Pacific, all making similar points.

However, as the City of London also notes, the take up of RegTech – though comparatively better in the FinCrime space than other areas – is still limited overall. A lack of practical rather than rhetorical regulator support has been proposed as one cause for this, and there are likely to be other barriers too. Some of the most innovative RegTechs are relatively small or young firms that find it difficult to satisfy the risk requirements of large and mature financial institutions. Even when the solution on offer is a good fit, it can sometimes be impractical for either side to work together.

In this session, the panellists will provide a pragmatic view on the state of RegTech adoption in the industry and seek to get to the root causes of its currently slow pace, looking at regulatory, commercial as well as technological points of friction. The panel will also look at ways the current initiatives to support RegTech, such as regulatory sandboxes and ‘Tech Sprints’, might be enhanced and expanded in order to ensure the sector meets its full potential in the future.

Host:

Christopher Woolard CBE, Partner, EMEIA Financial Services Consulting & Chair, EY Global Regulatory Network, EY LLP

Panellists:

Dr Sian Lewin, Co-Founder and Head of Client Delivery, RegTech Associates

Francesca Hopwood Road, Head of RegTech & Advanced Analytics, FCA

8:15 am
FinCrime’s Pivotal Moment - A conversation with Burkhard Mühl, Head of the European Financial & Economic Crime Centre, Europol

The 2021 Serious and Organised Crime Threat Assessment (SOCTA) from Europol, the EU’s policing agency, made for sombre reading. According to the report, organised criminality in Europe is more complex and fluid than ever before, with different criminal gangs working together ‘as needed’, on the basis of mutual self-interest. Unlike the old-fashioned ‘Godfather’ model of organised criminality imagined in films and TV, modern master criminals are now as agile and collaborative as the entrepreneurs of the technology sector. Laundering the funds generated by these illicit criminal activities has become as equally sophisticated as the predicate crimes themselves, with professionalised networks, often operating through legitimate business structures, insulated from effective disruption by systemic corruption of individuals in the public sector, financial institutions and professions. As a consequence, the management of illicit finance has become deeply rooted in societies and economies, with its scale and complexity probably significantly greater than previously thought.

In this interview, we explore these issues in depth with Burkhard Mühl, since December 2020 the Head of the newly created European Financial & Economic Crime Centre (EFECC) at Europol. Herr Mühl – a 35-year veteran of Austrian and European law enforcement – believes that serious and organised crime and illicit finance are now major challenges for the EU, and therefore need to be addressed not only with new vigour, but a more strategic approach that targets the ‘high value’ kingpins at the centres of the networks. He also contends that to put organised criminals and money launderers on the defensive, law enforcement agencies and their partners in the private sector will need to learn lessons from their opponents’ success – by becoming ‘masters of collaboration’ in their own right.

Interview with Burkhard Mühl, Head of European Financial & Economic Crime Centre, Europol        

9:00 am
Tackling the Dark Underbelly of the Illegal Wildlife Trade A presentation by Araluen Schunmann, Director, Pangolin Crisis Fund

Anti-financial crime practitioners know that the illicit trade in wildlife has become a major source of illicit funds in the global criminal economy. But what do practitioners know about how the criminals conduct their business? In comparison to illicit activities such as drugs and human trafficking, the modus operandi of illicit wildlife traders is much less well-known. There are good reasons for this, of course, given the relative immaturity of the international effort to tackle the problem. But even so, we are learning – slowly – about how the wildlife traffickers operate.

In this presentation, Araluen Schunmann, Director of the Pangolin Crisis Fund for the Wildlife Conservation Network (WCN), will explore how the trade works, providing insights into the international supply chain for wildlife, the demand and supply that drive the illegal market, and the important role that corruption plays in enabling the trade. She will also explore how law enforcement agencies and NGOs seek to investigate these crimes, while providing a frank assessment of the roadblocks they face. What good can a SAR do against a sophisticated international network, and what prospects are there for the investigation and prosecution of traffickers at the top of the criminal organisations, rather than lower-level operatives who facilitate the trade on a day-to-day basis? Providing a balanced view of where we are in the fight, the presentation will not only explore emerging strategies for tackling the trade, but also address what else will need to change for the international community to have a significant impact.

Presented by Araluen Schunmann, Director of the Pangolin Crisis Fund, ‎Wildlife Conservation Network

9:45 am
Fighting Kleptopia -A conversation with Tom Burgis, author of ‘Kleptopia: How Dirty Money is Conquering the World’.

Even a decade ago, the emergence of kleptocracy – a political system where leaders use their positions of power to enrich themselves – was seen by those living in ‘developed’ states as being a marginal risk that affected only poor or undemocratic societies. However, as we have learned since then, no society – however well-established – is immune from the lure of financial and political corruption.

One of the leading journalists chronicling the progress of kleptocracy across the world is Tom Burgis, an award-winning reporter and a long-standing member of the Financial Times’ investigations team. In his most recent book, Kleptopia, published in 2020, Burgis exposes how seemingly disparate events, such as a massacre on the Kazakh steppe or a stolen election in Zimbabwe, can be linked to a hidden web of connections that touches centres of power not only in Beijing and the Kremlin, but also the City of London and, ultimately, the White House.

In this session, Burgis will discuss the inner workings of this growing global network of kleptocratic elites, and the efforts of quiet heroes seeking to highlight this problem, such as the compliance officer-turned-whistleblower Nigel Wilkins, who features in the book. Burgis also will explore how half-hearted government and private sector initiatives have failed to challenge the problems of corruption and illicit finance so far, and consider more effective ways to take the fight to the kleptocrats, now.  

Interview with Tom Burgis, Investigations correspondent, Financial Times

10:30 am
From Siloes to Systemic Solutions: FinCrime Utilities - Long term solutions?

FinCrime professionals often argue that one of the major challenges they face is the fragmentation of the anti-FinCrime effort: not only between the public and private sectors, but between firms themselves. With each individual business seeking to identify high-risk clients and suspicious activities through their own resources alone, it can be relatively simple for sophisticated financial criminals to work around the system. One idea often discussed has been that of ‘utilities’: institutions pooling their resources and working together to undertake their FinCrime obligations jointly. The most common experiments so far have been with KYC utilities in Asia-Pacific, Africa and Europe. Separately, a group of five major banks in the Netherlands has also started building the world’s first Transaction Monitoring utility.

These kinds of projects - combining data or taking a systemic, network view - should in theory improve the industry’s ability to understand and tackle common risks. However, so far, this has not been fully demonstrated, and utilities have also generated substantial practical issues of implementation. Some of these have been unique to the specific requirements of the project at hand, whether KYC or monitoring, while others appear to be more common. Integrating the data from multiple diverse institutions has proved a technical headache for some in the KYC space already, and in a world where personal data privacy is increasingly privileged, data-pooling has faced major challenges from developments such as the EU’s General Data Protection Regulation (GDPR).  Surveying this complex landscape, the panel will assess the potential value that utilities can bring to different aspects of the fight against FinCrime, and the balance between risk and reward that might come with such ambitious collaborations.

Host:

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research    


Panellists:

Nick Lewis OBE, Managing Director, Conduct, Financial Crime & Compliance, Standard Chartered Bank

Helène Erftemeijer, KYC Lead, ING

Che Sidanius, Global Head of Financial Crime and Industry Affairs, Refinitiv

Lora von Ploetz, Director/Head of Global Financial Crime Unit, Commerzbank AG                                  

11:20 am
The Key to FinCrime? Encryption, Privacy Enhancing Technologies and the data-sharing challenge

A common refrain amongst FinCrime professionals is that it would be easier to take on the criminals if they were more readily able to share sensitive information between organisations. Whereas criminals have no barriers to worry about in this regard, those tasked with detecting and disrupting them have to follow closely the requirements of data and privacy law, which have often proved prohibitive.

For some time, the problem has been without a potential solution. However, over recent years, the development of advanced encryption techniques, often described as ‘Privacy Enhancing Technologies’ (PETs), have opened up new opportunities for smart data sharing. According to their proponents, PETs can help institutions combine and analyse sensitive data that remains can encrypted throughout – effectively ‘sharing’ without sharing.

The potential implications for financial intelligence partnerships are significant and have thus become a major topic of interest amongst FinCrime professionals. In this session, our experts will explore the promise of PETs: from the potential FinCrime ‘use cases’, the evidence of value and workability, to the practical challenges – from the technological to the regulatory – they might also bring.

Host:

Seán Doyle, Lead, Cybersecurity and Anti-Financial Crime, World Economic Forum

 
Panellists:

Rina Shainski, Co-founder and Chairwoman, Duality Technologies

Nick Maxwell, Head of the Future of Financial Intelligence Sharing research programme, FFIS Research

12:50 pm
FinCrime’s Wider Responsibility- Environmental, Social and Governance Reporting in FinCrime Compliance A presentation by Michael Rasmussen

In a world increasingly concerned with nurturing sustainability, businesses now take a greater interest in the wider impacts that they have on the environments and societies in which they operate. As part of this trend, Environmental, Social and Governance (ESG) reporting has become a common feature of how businesses seek to manage and explain their approach to these issues to regulators, investors, customers and employees.

Nonetheless, despite its recent spread, ESG reporting is often not fully understood, even in compliance tems. Although the issue of environmental impact is well-known, the full gamut of social concerns that need to be covered in ESG, from privacy, modern slavery, through to inclusion and diversity – are much less appreciated, as too is the role that governance needs to play in the management of financial crime risks such as fraud, bribery and corruption. To have an effective ESG program requires that financial crime compliance teams be a critical part of the reporting strategy.

In this session, Michael Rasmussen, aka ‘The GRC Pundit’, will help participants think through the essentials of an effective ESG program, and will cover: challenges of definition and scope; the clarification of regulatory and stakeholder requirements; the role that financial crime compliance teams need to play; and strategy and processes of ESG reporting. Michael is an internationally recognised commentator and consultant on Governance, Risk and Compliance (GRC) – a term he himself coined – and has over three decades of experience in the field. A popular presenter from our March conference, we are delighted to welcome him back

Presented by Michael Rasmussen, GRC Analyst & Pundit, GRC 20/20 Research

2:00 pm
The Real Ingredients of Virtual Compliance ‘Baking-in’ FinCrime good practice from the start

For entrepreneurs in any space there is often a desire to do things ‘differently’. Indeed, that is a prime motivation: to deliver a new product to customers. It can be tempting to focus on getting this right, providing a high-quality customer experience, and stimulating growth, to the exclusion of other concerns. Although compliance, regulation and risk management do not get ignored, they can slip down the list of priorities.

This has undoubtedly been a common challenge in the Virtual Assets sector, where innovators focused on developing new types of asset, product or service have sometimes found themselves dealing with issues of financial crime compliance last - with dire commercial and sometimes legal consequences. In some recent cases, the spread of stronger global AML/CFT requirements for the industry has led firms who did not factor such matters in from the start to go out of business. In other cases, failures to meet regulatory requirements have led to fines and regulatory censure.

If the Virtual Assets sector is to continue its remarkable growth, therefore, entrepreneurs and firms in the sector will need to develop sustainable ways in which to approach core compliance and risk management requirements from the start. In this session, our panel of experts will consider the ways in which Virtual Assets innovators have addressed these issues so far – successfully and otherwise – and seek to glean learning points for how Virtual Assets firms can ‘bake-in’ good practice, and develop sustainable FinCrime frameworks as an ingredient of long-term success.

Host:

• David Rowe-Francis, Founder, Praxis Compliance Consultants

Panellists:

Araba Eshun, Head of Compliance & MLRO, UK, Gemini Europe Limited

Caitlin Barnett, Director of Regulations and Compliance, Chainalysis                                                

2:50 pm
Crypto 2.0 – New ways of performing old tricks? Exploring Crypto Typologies with Nick Furneaux

Any sufficiently new technology can seem like magic to the uninitiated, and it can become easy to assume that its abuse by criminals is equally magical and just as perplexing. It can also become a natural next step to assume that there is a particular type of ‘crime’ inherent to the new technology in question.

Rarely in recent years have new technologies been so quickly framed in this way as blockchain and cryptocurrencies. FinCrime discourse has quickly assumed that not only is cryptocurrency inherently riskier than fiat currency, but that there is a particular form of distinctive crime – ‘crypto crime’ – that is intimately linked to it.

But despite these presumptions, the truth about the criminal abuse of cryptocurrency is considerably more prosaic. ‘Crypto crimes’ are in fact just good, old-fashioned crimes, with a new ‘virtual’ twist, according to Nick Furneaux, Managing Director of CSITech and author of Investigating Cryptocurrencies. In this session, Nick will follow up his popular talk from our March conference with an exploration of the classic criminal typologies that get applied to cryptocurrencies and provide potential investors with a range of issues to consider when dealing safely in this evolving market.

Presented by Nick Furneaux, MD at CSITech and CTO at Asset Reality                                                  

3:50 pm
Off the Crypto Rollercoaster Are stable coins and centralised digital currencies 'safe' alternatives?

In the face of soaring market values for a variety of cryptocurrencies, public authorities and established financial institutions across the world have been forced to start considering the implications of these assets’ wider usage. Cryptocurrencies are no longer seen to be a ‘fringe’ interest, or of little relevance to the wider economy.

Nonetheless, concerns continue about the perceived risks of market failure and abuse that come with the assets. Organisations in the public and private sectors are both trying to clarify their approaches to the issue. Some are rejecting crypto outright, while others are choosing to ride the rollercoaster. But between the extremes, others have been seeking to develop crypto in a more ‘risk friendly’ way. Private stablecoins – cryptocurrencies linked to the value of more tangible assets – are one proposed solution – while fully digitalised versions of pre-existing fiat currencies are another.

In this panel, our experts will explore the growing diversity of virtual and digital currencies, the likely future trends, and the growing role that governments and ‘big technology’ firms are seeking to play in the space. They will also ask whether these alternatives can really have the same market appeal as pure ‘crypto’ - without the potential risks.

4:40 pm
Scanning the Virtual Horizon The next steps for global Virtual Asset regulation

In March 2021, the Financial Action Task Force (FATF), the international standard setter for FinCrime, issued new guidelines on a risk-based approach to Virtual Assets and Virtual Asset Service Providers. Coming less than two years after its first guidelines on the area, the document has sought to clarify uncertainties, fill gaps, and update the rules in light of the fast-growing scope of the sector. Overall, the new guidelines have pointed towards a more stringent approach than before, with a widened definition of Virtual Assets, and additional references to stable coins, Decentralised Finance (DeFi) and Non-Fungible Tokens (NFT). Some FATF members have already starting taking a tougher line on the question, and those that have not are likely to follow suit in the near future.

But is this the right approach for Virtual Assets, or even the only approach? Is it possible to continue to apply a framework designed for fiat currencies to the virtual space? Or will a bespoke approach be required? In this panel, our speakers will review the current ‘state of play’ in the regulation of Virtual Assets, the philosophy behind regulators’ policies, and assess where regulators might go next. The panel will explore whether other regulatory models or bespoke alternatives might be applied to better effect, and the potential scope for regulatory innovation.

5:30 pm
Scams: Fuelling the Crypto Fire A presentation by Scott Johnson, Chainanalysis

In its 2021 Crypto Crime Report, Chainanalysis, a leading blockchain analysis company, found that scams – ranging from Darknet market abuse, extortion, phishing to Ponzi schemes – continue to be the highest-grossing forms of cryptocurrency-based crime, bringing in around $2.7 billion to criminals. Last year, scam-type crimes – especially fake investment schemes – were also affecting more individuals than ever before, with the number of separate payments to scam addresses rising from just over 5 to 7.3 million – a potential rise in victim numbers of more than 48%. Scams have always been big business for serious organised criminality, and the expansion of cryptocurrency usage has provided new options not only to make money, but to launder it too.In this session, we will be hearing from Scott Johnston, Head of Public Sector Outreach (EMEA) at Chainanalysis, the company behind the report, who will provide a realistic and evidence-driven overview of where we are with crypto-linked scamming. Scott – a former UK police officer with 18 years’ experience investigating serious organised crime, money laundering and emerging crypto threats – will help participants understand what the headline figures mean in practice, learning about 2020’s most significant scam-related cases and the likely trends in the crypto crime ecosystem in 2021. Scott will also explore how we can start to take ‘the fuel off the fire’, using blockchain analysis as a way to profile and track down scammers and identify new leads.

Presented by Scott Johnston, Head of Public Sector Operations, EMEA, Chainalysis                                                  


2021 Speakers | 22 - 23 June 2021

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