Plenitude Consulting

The UK Government announced a new sanctions package against Russia. The package of 107 sanctions is the largest since immediately following the invasion of Ukraine in 2022. Key parties targeted by the package include: ➡️ Producers and suppliers of Russian military equipment based in a range of third countries; ➡️ Senior North Korean officials responsible for the deployment of military forces to Russia; ➡️ Wealthy Russian individuals and businesses responsible for supporting the Russian war effort and strategic sectors of the economy; and ➡️ Ships responsible for transporting Russian oil. ✅ Firms should ensure sanctions screening systems account for the latest lists in line with technical policies. https://hubs.li/Q038KM1W0

The Wolfsberg Group elected Emma Molvidson as its new Co-Chair, effective January 1, 2025. ➡️ Molvidson, currently the Global Head of Financial Crime Prevention at UBS, has over 14 years of leadership experience in legal, compliance, and investigations; ➡️ She succeeds Joe Salama of Deutsche Bank, who had been praised for his contributions to the Group’s financial crime reform efforts; ➡️ Current Co-Chair Jen Calvery (HSBC) welcomed Molvidson's expertise, highlighting her legal and investment banking background as a valuable asset in advancing the Group’s agenda. ✅ Firms should continue to review best practice guidance published by the Group. https://hubs.li/Q037Kr1n0

The Holy Month of Ramadan is a time to reflect not only on our own blessings but to celebrate those who we live and work with to appreciate their love, support and loyalty. Wishing our colleagues, clients, and the wider Plenitude network Ramadan Kareem. May this Ramadan be successful for all of us and provide us with good health. #Ramadan2025

The 4th No Money for Terror #NMFT Ministerial Conference, hosted in Germany, brought together nearly 400 participants from over 60 delegations. The event focused on driving global initiatives to combat terrorist financing and strengthen international cooperation in tackling financial crime. Key themes from the conference include: ➡️ Multilateral cooperation: Recognising the benefits of and need for international cooperation to understand terrorist financing threats, strengthen legislation, and share information; ➡️ Digital channels: Understanding the importance of implementing the FATF guidance on virtual assets, particularly the travel rule, and the increasing threat posed by the blending of cash-based and digital financing methods; ➡️ Financial inclusion: Acknowledging the importance of financial inclusion for legitimate entities and the need for tailored risk assessments for non-profit organisations #NPOs particularly due to the misuse of FATF standards to supress civil society; and ➡️ Organised crime: Sharing best practice on addressing and dismantling links between organised crime and terrorism financing. ✅ Firms should review Counter Terrorism Financing #CTF control frameworks to ensure they are responsive to evolving threats. Learn more: https://hubs.li/Q037KlVG0

The Financial Action Task Force #FATF held the second plenary under the Mexican Presidency. The plenary brought together delegates from over 200 jurisdictions for 3 days of technical discussions on addressing AML/CTF/CPF risks. Key takeaways from the plenary include: ➡️ Jurisdictions under increased monitoring (the grey list): Laos and Nepal were added to the list while the Philippines was removed following the completion of their action plan; ➡️ Financial inclusion: Following public consultation, members agreed to revise the FATF Standards, simplifying the risk-based approach where risks are low to further promote financial inclusion; ➡️ Online child sexual exploitation: A new report was approved to examine financial flows and provide intelligence on disrupting online abuse; ➡️ Vice Presidency: Giles Thomson from the UK was appointed as the next FATF Vice President for 2025-2027; ➡️ Payment transparency, and complex proliferation financing and sanctions evasion: Consultations were agreed on both topics and will be published at a later date; and ➡️ Global engagement: Kenya joined the Cayman Islands and Senegal as a guest jurisdiction at the Plenary. ✅ Firms should ensure risk assessment frameworks reflect the changes to the FATF grey list and can review the Plenary’s outcomes to further understand the organisation’s priorities. Learn more: https://hubs.li/Q037ZyY-0

The Financial Conduct Authority #FCA and the Payment Systems Regulator #PSR released a feedback statement on big tech and digital wallets. The statement follows the regulators’ joint Call for Information #CFI in July which sought to understand the opportunities and risks associated with the increasing popularity of digital wallets. Focusing on the financial crime elements of the statement, key takeaways include: ➡️ Growth in usage: In 2023, roughly 20% of card users used digital wallets for over half of their transactions, with increased usage providing scammers with more opportunities for phishing attacks and social engineering; ➡️ Unauthorised transactions: Underlying card issuers remain responsible for complying with strong customer authentication #SCA requirements and digital wallets are expected to become increasingly targeted by fraudsters; and ➡️ Fraud liability: Although digital wallet providers may be responsible for enabling fraudulent transactions, card issuers ultimately remain responsible for the reimbursement of unauthorised payments. ✅ Card issuers regulated by the PSR and FCA should review their fraud prevention frameworks, ensuring robust controls are in place to effectively mitigate non-plastics fraud risks. Learn more: https://hubs.li/Q037KT_k0

The Payment Systems Regulator #PSR announced the next steps for the implementation of Authorised Push Payment #APP scams claims management requirements. ➡️ The regulator plans to launch a consultation in April 2025 seeking views on regulatory requirements for Pay UK’s reimbursement claims management system #RCMS for APP scam claim management and data reporting; ➡️ The requirements will aim to promote consistency across claims management and reporting supported by a centralised system implemented by Pay UK; and ➡️ RCMS requirements could be introduced in late 2025 at the earliest, with the potential implementation date being one of the aspects that will be covered in the upcoming consultation. ✅ Firms should ensure their APP fraud prevention controls are robust and can prepare to respond to the PSR’s upcoming consultation in April 2025. https://hubs.ly/Q0374PLY0

Transparency International released the 2024 Corruption Perceptions Index #CPI. The index ranks 180 countries and territories across the global on their perceived level of public sector corruption on a scale from 0 to 100. Key insights from this year’s index include: ➡️ Since 2012, 148 countries have maintained or lowered their scores; ➡️ The average Middle East and North Africa #MENA score rose by 1 point to 39, the first increase in over 10 years; ➡️ Sub-Saharan Africa continues as the region with the lowest average score with progress hampered by climate change and conflict; ➡️ The Asia Pacific #APAC region’s average score declined despite a variety of countries improving; and ➡️ Western Europe and the EU declined in average score due to poorly enforced legislation and leaders’ perceived business interests. ✅ Firms should review their Risk Assessment frameworks to ensure they account for evolving bribery and corruption risks across relevant jurisdictions. 💡 Plenitude #Compass has been developed specifically for Financial Crime Compliance teams to keep you informed of changes to geographical risk and its implications for numerous financial crime controls Learn more: https://hubs.li/Q037t7GW0

UK Finance published guidance on the Failure to Prevent #FTP offence introduced by the Economic Crime and Corporate Transparency Act 2023 #ECCTA. The guidance is split into 3 key sections: ➡️ Interpretation of the act including the definition, scope, and defences for the offence; ➡️ Reasonable prevention procedures covering the Financial Conduct Authority’s #FCA 6 principles for effective control frameworks; and ➡️ Circumstances in which firms cannot reasonably be expected to implement FTP controls, such as those arising from data protection restrictions or existing contractual agreements. 🗓️ Firms have until 1st September 2025 to ensure fraud risk assessments and prevention controls cover the FTP offence in line with the ECCTA’s requirements. 💡 Plenitude’s Fraud Prevention Practice conducts independent assessments to help clients identify control gaps and maintain compliance in an evolving threat and regulatory landscape. Learn more: https://hubs.ly/Q0374C9-0

The Office for Financial Sanctions Implementation #OFSI released a financial sector threat assessment report. The report aims to provide information on suspected sanctions breaches and assist stakeholders in taking a risk-based approach to compliance. Key takeaways from the report include: ➡️ It’s likely that some UK financial services firms haven’t disclosed all suspected breaches to OFSI; ➡️ Most instances of non-compliance are due to poor maintenance of frozen assets, breaches of OFSI license conditions, inaccurate ownership assessments, and inaccurate UK nexus assessments; ➡️ Russian designated persons #DPs are increasingly using enablers to breach UK financial sanctions; ➡️ Most enabler activity relates to maintaining Russian DP lifestyles and assets, with it highly likely that payments are made through non-banking payments service providers #NBPSPs; ➡️ Some enablers claim ownership of frozen assets in an attempt to front for DPs; and ➡️ Enablers use other payment methods such as crypto-assets to breach UK financial sanctions. ✅ Firms should review their sanctions controls and screening systems to ensure they are not facilitating the breach of UK financial sanctions through the circumstances outlined in the report. Learn more: https://hubs.ly/Q0374B4v0