Ross Longmore

The three stages of laundering money are: 1. Placement: The ""dirty money"" or proceeds of crime is placed in the financial system; 2. Layering: Moving funds around financial services, with a view to further disguising the proceeds of crime; and 3. Integration: When the money launderers can withdraw the funds from the financial system and use this for seemingly ""legitimate"" activities. Click below for our online Anti-Money Laundering training course, with access to our Free Demo Course.... #AML #AntiMoneyLaundering #RQCGroup

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Metro Bank fined nearly £17m for failure to monitor potential money laundering #Metro #MetroBank #AML #MoneyLaundering #Banking #FCA #TSGTSG #SoftwareAssurance #BusinessSystems #BusinessSolutions #SoftwareTesting #SoftwareSolutions #QA #SoftwareQualityAssurance #TestDrivenDevelopment #TestManagement https://soamp.li/m6h2

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It’s time for a wake-up call for AML compliance. Starling Bank's recent £29m fine for AML failures is a dire reminder of the compliance challenges in the financial sector. Key takeaways from the FCA's findings: 1️⃣ Leadership is crucial - compliance starts at the top 2️⃣ Systems and controls must evolve with your growth 3️⃣ Talent acquisition in specialized areas is make-or-break 4️⃣ Effective management information is non-negotiable But, challenger banks have a unique opportunity to turn these challenges into advantages. How? 🔍 By leveraging innovative tech like Federated Learning 🚀 Building compliance frameworks from the ground up 💡 Viewing compliance as a competitive edge, not a burden Remember, growth without robust compliance is a high-risk strategy. But get it right, and you're not just avoiding fines - you're building trust and long-term success. Take a look at our latest blog for more: https://lnkd.in/e6--gasb #ChallengerBanks #FinTech #AMLCompliance #FinancialCrime #RegTech

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🏦Metro Bank's $17M Fine: A Wake-Up Call for Banks #AML #MetroBank #FCA #MoneyLaundering #FinancialCrime #Compliance #RegulatoryEnforcement 🔰The UK's Financial Conduct Authority (FCA) has imposed a $17 million fine on Metro Bank for potential money laundering failures. This significant penalty serves as a stark reminder of the importance of robust Anti-Money Laundering (AML) controls. 🚩Cause: Between June 2016 and December 2020, Metro failed to have the right systems and controls to adequately monitor over 60m transactions, with a value of over £51bn, for money laundering risks. The FCA identified weaknesses in Metro Bank's customer due diligence and risk assessment processes, including: - Inadequate customer verification - Insufficient risk assessment and monitoring (transaction monitoring was automated in June 2016) - Failure to report suspicious transactions 🚀Lesson Learnt: 1. Risk-Based Approach: Ensure customer risk assessments are thorough and ongoing. 2. Customer Due Diligence: Verify customer identities and beneficial ownership. 3. Transaction Monitoring: Implement effective suspicious transaction detection and reporting. 4. Ongoing Training: Educate staff on AML regulations and best practices. 5. Continuous Improvement: Regularly review and enhance AML controls. 📍Key Takeaways: - AML compliance is non-negotiable. - Regulatory scrutiny is increasing. - Financial institutions must prioritize risk management. Read the full report @ https://lnkd.in/giDP6fVg Share your thoughts: How can financial institutions strengthen their AML controls? #FinancialIntegrity #AMLCompliance #RegulatoryEnforcement #MoneyLaunderingPrevention #FinancialCrimePrevention Engage with the post: Like Comment Share Follow me for more AML insights!

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This isn't really a new theme. Efficient controls are not the same as effective controls. Any decent Compliance Monitoring Plan worth the paper it is written on will demonstrate exactly that. FATF ratings are just a measure to use when constructing your own internal country risk assessments. Never go below their rating, but there is no problem to keep the likes of the Cayman UAE at high risk. #aml #compliance #monitoring #fatf #jurisdiction #mlro #mlco #risk #financialcrime #fincrime https://lnkd.in/ewVR4ruD

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📢 Last week CB Payments Limited (CBPL), a UK-registered E-Money was fined £3.5m The Financial Conduct Authority issued a Final Notice to CBPL, highlighting areas for improvement in their financial crime compliance processes. This serves as a valuable case study for all #fincrime professionals. The key points: ❌ Penalty: CBPL received a £3.5m fine, reduced from £5m due to early settlement. ❌ Breach of Requirements: CBPL breached a Voluntary Requirement (VREQ), an FCA supervisory tool that restricts certain business activities to mitigate risk while the firm enhances its compliance framework. Over three years, CBPL onboarded 13,416 high-risk customers against VREQ restrictions, leading to $24.9m in prohibited deposits and $226m in crypto transactions. ❌ What Went Wrong: The FCA identified significant gaps in CBPL’s automated onboarding systems and financial crime controls. Key issues included inadequate pre-implementation testing, incomplete requirements given to the tech team, and ineffective ongoing monitoring, resulting in repeated non-compliance. Lessons Learned: ✅ Strengthen Controls: Ensure financial crime control frameworks are effective and regularly updated. ✅ Testing: Conduct thorough pre-implementation testing for new controls and continuously monitor their effectiveness. ✅ Record-Keeping: Maintain comprehensive records of all compliance efforts, including design, testing, and implementation steps. ✅ Continuous Monitoring: Implement effective monitoring systems to quickly detect and address any breaches. Utilise dashboards and other tools for real-time compliance tracking. ✅ Timely Remediation: Address any identified weaknesses promptly. For further details, review the full Notice here https://lnkd.in/e9ZMtc_2 #FinancialCrime #MLRO #Compliance #FCA #Crypto #AML #Regulation #effectiveness

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❌ You can't afford to have a backlog. In Financial Crime, some backlogs will push you dangerously close to the edge of non-compliance (if not over the edge). But it happens.   ℹ️ The team at DCM has put together a list of avoidance techniques to detect issues and promote a culture of vigilance. Are your controls holding up and are they effective? Reach out to our team if you need any support: [email protected] #FinancialCrime #KYC #Backlog #Remediation #ManagedService #DearCEO #AMLCompliance

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🚨 Anti-money laundering (AML) checks have been a miss at Metro Bank (UK), who now face a nearly £17m fine from the Financial Conduct Authority for gaps between 2016 and 2020, reports The Guardian. 👀 Read more in the article below. 👉 https://lnkd.in/ehTZRKFV 💡 Oversight is essential. A proactive approach to AML is not just about compliance — it's a fundamental responsibility. Secure systems foster trust, protect customers, and uphold the integrity of the financial sector. 🌟 Ready to enhance your AML strategy? Contact us today to learn more about our advanced fraud monitoring systems and how we can help safeguard your organization. #EmbeddedFinance #Banking #Fintech #Finance #Payment

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So we've done something... AML Compliance officers, EVERYWHERE, would prefer to have daily, ongoing customer screening and monitoring. But they make a Faustian bargain. They opt for annual, quarterly or annually. They trade their sleep during their rescreening periods, for cost. Well, now, all Complytek AML compliance officers can rest easy. It will cost the same fixed, flat fee whether you choose to rescreen them once a year, or daily. Come get sleep. You're home. #AML #AMLScreening

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Open Banking #OBL released its Financial Crime Report 2024, providing key insights into financial crime risks and mitigation strategies within open banking journeys. The report highlights the evolving challenges of combating fraud and financial crime in the rapidly growing open banking ecosystem. Key Takeaways Include: ➡️ Total APP fraud losses in the first half of 2024 amounted to £213.7 million across 178,230 payments, underscoring the scale of fraud risks in open banking transactions​; ➡️ Fraudsters are exploiting vulnerabilities in payment authorisation processes, highlighting the need for robust security measures and enhanced monitoring​; ➡️ Collaboration between financial institutions and technology providers is critical to mitigating risks and improving fraud detection within open banking journeys​; and ➡️ The report emphasises the importance of consumer education in identifying and avoiding scams within the open banking environment​ ✅ Financial institutions should continue to prioritise robust fraud prevention strategies to safeguard the integrity of open banking ecosystems. 💡 Learn more about Plenitude’s Fraud Prevention Services and how we help clients enhance their fraud prevention mechanisms: https://lnkd.in/eFGHUH5U https://lnkd.in/ejgyM87t

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Metro Bank’s recent £16.7 million fine highlights a serious lapse in monitoring systems that left millions of transactions unchecked for financial crime risks between 2016 and 2020. Watch as we break down what went wrong and the importance of robust AML/CFT controls in today’s financial landscape, in this week's Weekly Words of Wisdom. #AML #FinancialCrime #Compliance #MetroBank

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✍️ New article: Suspicious Activity Reporting (SAR) Responsibilities for Payment & Emoney Firms The FCA recently sent a letter to some payments and Emoney firms, where they were reminded of their responsibilities regarding Suspicious Activity Reporting (SAR).   As financial crime continues to evolve, regulators have stressed that firms in the payments and Emoney sectors must prioritise their SAR framework.   Our latest article provides key insights into enhancing your SAR process, including:   ·      Establishing robust detection systems (manual and automated) ·      Senior oversight for effective alert management ·      Keeping accurate SAR volumes to meet regulatory standards ·      Regular staff training to combat financial crime   Read the full article now: https://lnkd.in/e76pWM2m   #Payments #Emoney #EMI #financialcrime #antifinancialcrime #SAR #FCA #Compliance

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𝐀 𝐋𝐞𝐬𝐬𝐨𝐧 𝐢𝐧 𝐑𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝐂𝐨𝐦𝐦𝐢𝐭𝐦𝐞𝐧𝐭𝐬 Recently, Starling Bank was fined £29 million by the UK's Financial Conduct Authority (FCA) for failing to comply with previously agreed-upon requirements. The FCA found that Starling did not properly adhere to financial crime prevention measures, including screening for financial sanctions and managing high-risk customers. While designing a robust risk environment is a critical objective for every compliance department, this case clearly highlights that fulfilling commitments made to regulators is of utmost importance. Starling's fine emphasizes that 𝐚 𝐜𝐨𝐦𝐩𝐚𝐧𝐲'𝐬 𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐭𝐨 𝐜𝐨𝐦𝐩𝐥𝐲 𝐰𝐢𝐭𝐡 𝐚𝐠𝐫𝐞𝐞𝐦𝐞𝐧𝐭𝐬 𝐦𝐚𝐝𝐞 𝐰𝐢𝐭𝐡 𝐫𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝐛𝐨𝐝𝐢𝐞𝐬 𝐢𝐬 𝐩𝐚𝐫𝐚𝐦𝐨𝐮𝐧𝐭. Key takeaways for businesses: 1) Compliance is a continuous process - Regularly review and update your systems and controls to meet regulatory expectations and avoid potential fines. 2) Risk assessments are essential - Frequently evaluate your risk exposure and adjust your AML program accordingly to maintain compliance. 3) Engage with regulators - Maintain open communication with regulatory authorities and demonstrate transparency in your financial crime prevention efforts. In the ever-evolving fintech landscape, businesses must prioritize adherence to their commitments and foster a strong compliance culture to prevent costly penalties and damage to their reputation. It's all about commitment! #fintech #fincrime #aml #screening #sanctions

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THE WEEK IN FINANCIAL CRIME The UK’s Payment Systems Regulator (PSR) has proposed a new reimbursement cap for victims of APP fraud to enhance consumer protection and incentivize financial institutions to “implement enhanced fraud prevention tools.” The proposed cap would be reduced from £415,000 to align with the Financial Services Compensation Scheme limit of £85,000. After considering responses to the consultation, the regulator plans to finalize the approach by the end of September, with the implementation date for the protections remaining unchanged on October 7. The Ministry of Home Affairs (MHA) in Singapore has proposed a new bill allowing the police to instruct banks to limit the accounts of individuals suspected of being targeted by scams. This comes in response to the city-state seeing a 50% increase in scam and cybercrime cases in 2023, with job scams, e-commerce scams, fake friend call scams, phishing scams, and investment scams being the top concerns. Under the Protection from Scams Bill, the police would have the authority to issue Restriction Orders (ROs) to banks to temporarily prevent people from sending money to scammers. The MHA has announced the bill will soon become law and has called for public feedback by September 30. On August 28, FinCEN issued a final rule imposing AML and KYC obligations on registered investment advisers (RIAs) and exempt reporting advisers (ERAs). The rule aims to help safeguard the investment adviser sector from illicit finance activity. It follows a February 2024 risk assessment highlighting numerous cases where sanctioned persons, corrupt officials, fraudsters, and other criminals have exploited the investment adviser industry to access the US financial system and launder funds. The deadline for compliance with this rule has been extended from the date originally set out in the NPRM to January 1, 2026.

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The FCA has fined CB Payments Ltd over £3.5 million pursuant to regulation 51(1)(a) of the Electronic Money Regulations 2011 in relation to financial crime controls. This is the first time that the FCA has taken enforcement action using these powers. In this article, partner David Capps and the team consider the decision and its possible implications for firms, including banks, payment services institutions, E-money institutions and cryptoasset firms. Read the full piece by clicking below. #DisputeResolution #Regulatory

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AML NEWS: FCA imposes its largest #fine of this year. It has fined Starling Bank £29m for #financialcrime failings relating to its financial sanctions screening. The regulator's Joint Executive Director of Enforcement and Market Oversight, commented that "Starling’s financial sanction screening controls were shockingly lax. It left the financial system wide open to criminals and those subject to sanctions". The #regulator highlighted that this case took 14 months from opening to achieving an outcome. This compared to an average of 42 months for cases closed in 2023/24. Starling Bank's chairman said "we have invested heavily to put things right, including strengthening our board #governance and capabilities". #antifinancialcrime #AML #sanctions #compliance #eigerregulatorypartners https://lnkd.in/ejjd7CrR

This case highlights an ongoing challenge in financial crime prevention – the concealed identities of true business owners. Which is why beneficial ownership checks are essential in any robust AML strategy. When onboarding clients or conducting ongoing due diligence, identifying the ultimate beneficial owners (UBOs) is not just a regulatory requirement – it’s fundamental to understanding the risk level a client may pose. Hidden ownership structures and complex corporate arrangements can be a red flag, potentially pointing to illicit activities, tax evasion or even financing terrorism. https://lnkd.in/eUUpT6JJ

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🚀 Starling Bank, once heralded as a rising star among UK challenger banks, now faces significant challenges in the wake of a £29mn fine from the FCA for “shockingly lax” financial crime controls. This recent regulatory scrutiny highlights the complex balance between innovation and compliance in the banking sector. ⚠️ The bank’s reliance on the pandemic-era Bounce Back loan scheme and failures in its anti-money-laundering framework have cast a shadow over its trajectory, making an IPO unlikely in the near term. ⚖️  As the FCA continues to tighten regulations, smaller digital banks face the difficult task of disrupting the market while adhering to increasingly stringent compliance requirements. 💡  What can challenger banks do to balance innovation and regulation? With comment from Laura Eshelby, Abdulali Jiwaji and Jonathan Fisher KC Sally H. reports https://lnkd.in/ePkP7kSt

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