00:00

his road is to identify regulatory

00:01

changes and lead programs of action

00:04

with the sole purpose of enhancing the

00:06

fight against financial crime

00:08

more effectively and delivering the best

00:10

possible outcome for the industry

00:12

his most notable awards include

00:15

receiving the potential award for

00:16

managing the 2079

00:19

financial crisis and a driving force

00:21

behind representatives impact company of

00:23

the year award

00:24

in 2019. over to you mr siddangus thank

00:30

you very much

00:31

uh very humbled by the invitation um

00:34

and and you know really look forward to

00:37

to today's discussion uh i hope you are

00:39

all well all the attendees it's been an

00:42

extraordinary

00:43

year so i hope you and your families are

00:45

all well

00:46

uh and safe uh hopefully next year or

00:50

certainly next time

00:51

we can do this in person uh i very much

00:54

look forward to visiting

00:55

wonderful india which i haven't had the

00:57

privilege to do yet

00:58

uh so hopefully we'll will will come out

01:01

of this uh

01:02

hopefully soon and um and look forward

01:04

to look forward to doing that

01:06

um so yeah so very briefly what i

01:08

thought i would do today

01:09

is share with you our perspective in

01:12

terms of what some of the

01:14

regulatory trends uh in the fight

01:16

against financial crime are

01:18

also some of the industry trends that

01:20

we're seeing

01:21

and really how increased collaboration

01:24

all across the public and the private

01:26

sector is reshaping

01:28

uh how we tackle financial crime how we

01:30

identify

01:31

financial crime uh and how we make the

01:34

whole system

01:35

much more effective so hopefully

01:38

that will that fits well within the

01:40

agenda uh what i will do is have it

01:42

some opening remarks for about 20 to 30

01:44

minutes uh and then

01:46

uh hopefully open it up for for q a but

01:49

please do

01:49

send your questions to the chat chat box

01:53

as well so without further ado

01:57

let me share with you uh the

01:59

presentation that we've prepared

02:02

and hopefully you can you can all see

02:04

that

02:05

and again one of the privileges of the

02:09

work that we do

02:10

is because we service so much part of

02:13

the anti-financial crime ecosystem

02:15

whether it's law enforcement the banking

02:17

community and non-governmental

02:19

organizations

02:21

and many others you know we have a

02:23

unique perspective in the sense of

02:25

actually looking at some of the trends

02:27

uh from from a holistic point of view

02:29

but also from a regional

02:31

point of view as well so hopefully we'll

02:33

give you um some of that

02:35

indications of where things are and

02:36

where things are heading

02:39

so without further ado i'll try to the

02:41

agenda for today which is a it's a broad

02:44

agenda i'll try to do my best to cover

02:46

most of these points

02:48

um i'll give you a little bit of a

02:50

flavor for what's happening

02:52

in certain regions i'll also talk about

02:55

some of the key

02:56

themes that we see dominate the policy

02:59

discussion

03:00

uh and also the focus areas in the next

03:02

few years

03:04

then we'll talk about some of the

03:06

industry trends the risks

03:08

and use of technology and this comes on

03:10

the back of a

03:11

report that we just released

03:15

last week in fact which is part of our

03:17

annual

03:18

risk and compliance report that will

03:20

reflect some of the risks but also some

03:22

of the

03:23

potential opportunities in the use of

03:25

technology

03:27

we'll talk about public private

03:28

partnerships this is not a new

03:31

term uh or a new concept but certainly

03:34

within the last several years there's

03:35

been a real step change

03:37

and shift and focus on information

03:40

sharing

03:40

partnerships and we'll give you some

03:42

examples

03:43

uh on on how we as a company are

03:46

collaborating

03:47

and what we're doing in that space focus

03:49

on

03:50

on some of the challenges that some of

03:52

these public private partnerships are

03:54

currently

03:55

facing including the challenges to scale

03:58

the increase in regional coverage and

04:00

some other um

04:01

issues that that they're facing that

04:03

we're hoping to solve

04:06

and then i'll also talk a little bit

04:08

about one of those public private

04:10

partnerships

04:11

uh called the global coalition to fight

04:13

financial crime

04:15

which is less about information sharing

04:17

partnerships from an operational level

04:19

but it's much more about engaging with

04:21

senior policymakers

04:23

who are currently undergoing significant

04:26

legislative change all across the world

04:28

and how we can bring our different

04:30

expertise

04:32

and best practice to the table whether

04:34

you're from a banking community

04:35

whether you're a fintech organization

04:38

with your crypto asset organization with

04:41

an ngo

04:42

and how we can bring all that to bear to

04:44

inform policy makers to ensure that any

04:46

legislative

04:48

you know changes and and manifestations

04:51

is really

04:51

you know they're informed by the best uh

04:53

best thinking that's that's out there so

04:55

we'll talk a bit

04:56

about what we're doing in that space and

04:58

also in fact that we're going to focus

05:00

our attention on asia in the next year

05:02

or so

05:04

um and then there's some additional

05:06

material that i'm not going to go

05:07

through it's more for your education uh

05:10

in terms of what we see are financial

05:11

crime priorities and the convergence in

05:13

fact between the sustainability agenda

05:16

and the financial crime agenda but

05:18

we can leave that for for for another

05:20

session but it's there for

05:21

for you to review if that's of interest

05:27

so let's take a step back um as many of

05:30

us

05:30

know who've been part of the financial

05:32

crime

05:34

fight for for a number of years that the

05:37

level of focus uh and the regulatory and

05:40

policy focus

05:41

on financial crime uh has really

05:45

you know gone beyond just the compliance

05:47

professionals

05:48

and in fact has evoked real scandals and

05:51

in a really evolved

05:53

a consciousness that we haven't seen

05:55

before

05:56

in terms of the public imagination on

05:57

these issues

05:59

a uh the eu has will release

06:03

an unprecedented legislative package on

06:05

anti-money laundering

06:06

legislation uh which in effect is well

06:09

it's probably

06:10

the most consequential in modern history

06:12

in terms of what they're trying to do

06:14

and we'll talk a little bit about what

06:15

those what those issues are

06:18

we've seen in the u.s uh in january 2021

06:22

uh past the aml act of 2020

06:26

which again is considered to be the most

06:28

significant

06:29

legislative package uh since the u.s

06:31

patriot act in 2001.

06:34

we've even seen the vatican being

06:37

brought into some of the scandals

06:40

due to an unprecedented amount of fraud

06:42

and corruption

06:43

and a number of areas including the

06:46

london real estate

06:47

and even money being that's that was

06:49

intended to use

06:51

to help free hostages were in fact

06:55

siphoned off and used for other purposes

06:58

we've also seen focus on on other

07:02

issues like human rights uh and

07:04

modern-day slavery

07:06

uh we've seen the eu for instance take

07:08

real action against many countries

07:09

including russia

07:11

china and others um on on sanctions

07:14

violations as far as human rights is

07:15

concerned

07:18

of course we all know about the growth

07:20

of crypto firms

07:21

um and that that segment has been

07:25

prone and unfortunately been used for

07:27

fraud

07:28

so there's a big focus both at the

07:30

financial action task force level

07:32

uh but also by many law enforcement and

07:34

regulators uh on

07:35

in the space and then of course the

07:38

pandemic

07:39

in the impact that pandemic has had on

07:41

all of our lives

07:42

including the financial crime space uh

07:45

the fact that we all work at home

07:47

the fact that we're even more now

07:48

dependent on technology than ever before

07:52

that has ris you know that has given

07:53

away to to

07:55

real levels of fraud and corruption

07:59

on top of which the unprecedented

08:00

stimulus packages

08:02

that have been issued to to support the

08:06

healthcare sector

08:07

uh and to secure healthcare products has

08:10

also been unfortunately been exploited

08:12

by criminals so there's a lot there in

08:15

terms of

08:16

that space including of course the focus

08:18

uh on

08:19

environmental crime uh in the fact that

08:22

the pandemic as far as we understand was

08:25

partly the result

08:26

of the interaction of wildlife

08:28

trafficking

08:30

uh in certain parts of china and so the

08:32

focus and the awareness

08:34

of our environmental crime has now

08:36

reached at the highest level whether

08:38

it's g20

08:39

the financial action task force that

08:40

just released a report in july

08:43

in fact on this issue and we'll talk

08:45

about what we consider to be the

08:47

the key issues and the key trends in

08:50

that space

08:53

and again uh moving on to that financial

08:56

crime is no longer seen as just another

08:57

compliance

08:58

uh topic it really is understood now

09:01

about the social

09:02

impact that it can have um we all aware

09:06

of

09:06

uh the scourge of modern-day slavery

09:09

there's more you know there's more

09:10

individuals now

09:11

caught in in slavery than there were

09:13

when when slavery was legal

09:15

and one-fourth a quarter of those

09:18

victims are children

09:20

and there's a real focus i think both

09:22

from policymakers but also from many

09:24

other

09:25

organizations including our own to

09:26

really look at modern day slavery in

09:28

supply chains

09:29

uh and this also is tied into the focus

09:31

on human rights in which modern day

09:33

slavery

09:34

part article four is this a subcomponent

09:37

of that but i think there's going to be

09:38

much more focus

09:39

on the on the impact of this issue

09:42

and and for us to find a way to share

09:45

information to share typologies to

09:47

really to tackle this

09:48

to tackle this horrible horrible uh risk

09:51

issue

09:53

there's also recognition that again

09:55

financial crime

09:56

is no longer seen as just another

09:58

compliance issue

09:59

in the fact that with the scandals that

10:02

we've seen

10:03

all across the world that actually

10:04

impacts the financial stability

10:06

of the banking system uh the stability

10:10

of uh you know of many many countries

10:13

because

10:13

frankly bank assets in many countries

10:17

are are multiples that of the country's

10:19

gdp

10:20

if we look at danske bank as just one

10:22

simple example

10:24

the danish central bank

10:28

admitted that because of the danske bank

10:30

scandal a few years ago

10:32

that in fact it had really put into

10:34

focus the credit rating of the entire

10:36

country

10:37

it had put into focus uh the stability

10:39

of the banking system as a whole so

10:41

there's a

10:42

there's a broad recognition uh that this

10:44

is a prudential issue this is a

10:46

macroeconomic

10:47

stability issue and in fact it's also an

10:49

issue that affects

10:51

capital flows investment flows foreign

10:53

direct investment

10:54

for many emerging economies and we've

10:56

had discussions

10:57

on this issue in south africa and many

10:59

other countries that have been

11:01

rocked by scandals by corruption

11:03

scandals and the impact that that has on

11:06

foreign direct investment

11:07

and other companies willing to to to

11:10

to increase and invest in their

11:12

operations within those

11:13

within those jurisdictions and then

11:16

turning back

11:17

again to the environmental crime we

11:19

definitive

11:20

refer to this issue as green crime uh

11:23

that is the fact that

11:24

um green crime is a broad term

11:28

that looks at not just wildlife

11:30

trafficking

11:31

but a whole slew of interconnected risk

11:33

typologies

11:34

illegal logging illegal fishing

11:38

and when you combine that holistic view

11:41

that in fact green crime under our very

11:44

noses

11:44

is probably one of the largest if not

11:47

the largest

11:48

um criminal activity when you combine

11:53

all of those risk typologies and it's

11:55

the issue

11:56

about we need to stop looking at

11:58

environmental crime of green crime as we

12:00

call it

12:00

as simply as another sustainability uh

12:04

topic but in fact it's about peace and

12:06

security

12:07

uh if we just turn our attention to the

12:09

incredible impact and devastation on our

12:12

families on our economy

12:15

uh then we actually have to take this

12:16

issue much more seriously

12:18

than we had in the past we first

12:20

launched

12:21

this topic in in january 2019

12:25

at the annual meeting at the world

12:27

economic forum at davos

12:30

unbeknownst to us and this is before the

12:32

pandemic really had

12:34

blossomed uh unfortunately and

12:36

devastated

12:37

and with this devastating effect

12:40

and from january 2019 to now

12:44

we have of course seeing the the

12:47

incredible impact that this issue has

12:48

had

12:49

not only in terms of raising awareness

12:51

about the transnational threat that

12:53

green crime has

12:54

but we also know from the world economic

12:56

forum that over 50 percent of global

12:57

global gdp

12:58

is is exposed to the loss of nature and

13:01

we

13:02

need to recognize that the criminal

13:03

criminal element here has a

13:06

significant impact on this issue

13:09

and through various events and surveys

13:13

and engagements throughout the industry

13:15

whether it's in compliance

13:16

sector the fintech sector the capital

13:19

market sector

13:20

the the response to some of our

13:22

questions were quite

13:23

um quite astounding when we asked

13:27

very simple question do you think that

13:29

green crime is a threat to peace and

13:30

security

13:32

anywhere between 70 and 80 said yes

13:36

uh when we asked should in fact green

13:38

crime receive equal attention

13:40

as money laundering and and uh in

13:42

terrorism financing

13:44

again 70 to 80 said yes and that range

13:48

really depended on which sectors and

13:49

which industries

13:50

that you asked but again across range of

13:53

of the of the industry at large

13:56

not just the compliance sector

13:59

that's even more uh eye-opening

14:03

is we ask the question should in fact

14:05

green crime be

14:06

added uh to the or the equal side

14:10

as a term be added to the international

14:13

criminal court

14:14

list of international crimes alongside

14:17

crimes against humanity

14:18

for instance uh and all you know over 80

14:22

percent

14:22

agreed with that so there's even a

14:24

momentum

14:26

now for the international criminal court

14:28

to add equal side

14:30

as a measure of real damage that it has

14:33

not only on our peace and security right

14:35

now but

14:36

but clearly on on the future

14:39

you would have seen that financial asset

14:41

task force i've issued a paper

14:43

as i mentioned just last week

14:46

you would also see that the g20 issued a

14:48

real strong statement

14:50

on environmental crime and we expect

14:53

that this not only to be an issue

14:54

that affects the financial services

14:56

industry and fintechs but also the

14:59

transport sector the manufacturing

15:01

sector

15:02

in other or organizations really to look

15:04

at supply chain risk

15:07

and also the impact that those companies

15:09

have they're the digital

15:11

and sustainable sustainable footprint

15:13

all across the world so this will no

15:15

longer be

15:16

seen in our view as looking at

15:18

sustainability in terms of what we

15:20

should do

15:21

but in fact looking at green crime on

15:23

issues that we should not do so these

15:25

will be they'll i think there'll be more

15:26

sanctions

15:27

uh issued there'll be more enforcement

15:30

uh by

15:30

law enforcement on these issues

15:35

and uh as as many of you will know um

15:40

or at least be aware i mentioned that

15:41

the unprecedented regulatory reforms

15:44

globally

15:45

i mentioned very quickly the u.s aml act

15:48

of 2020 we'll talk a little bit about

15:50

the eu's legislative package in a moment

15:53

but as i mentioned the environmental

15:55

crime agenda

15:56

the b-20 which is the industry advises

15:59

to the g20

16:00

are promoting public-private

16:01

partnerships and information-sharing

16:03

partnerships in a way that we haven't

16:05

done in the past

16:07

we'll talk a little bit about what we're

16:09

doing on information sharing

16:10

partnerships and how there's varying

16:12

there's new trends and new types of

16:14

those uh

16:15

of those of those frameworks that are

16:17

coming to four

16:18

and we'll talk a little bit about some

16:20

of the examples that we're involved with

16:22

we all know that the the concept of

16:25

obligated entities

16:27

and in terms of who's required to follow

16:29

anti-money laundering rules

16:31

and screening rules and customer due

16:32

diligence has been expanded to include

16:34

other sectors as we know with crypto

16:36

assets as just one example

16:39

and then we'll talk a little bit about

16:40

industry uh trends risk and the use of

16:43

technology

16:44

and then we'll we'll we'll finalize with

16:46

a discussion on

16:47

the global coalition

16:51

so let's turn our attention to the eu

16:52

for a moment

16:54

because it's this is um hasn't been

16:57

released yet

16:58

so it's not public but we've seen copies

17:01

of the aml's eu's aml package and we

17:03

think that this is a precursor

17:06

of regulatory uh trends that are going

17:08

to spread all across the world in many

17:10

different

17:11

jurisdictions and regions i won't

17:14

belabor on all of them

17:15

but i would focus on a few the first

17:19

is that for the first time the

17:22

anti-money laundering rules will move

17:25

from

17:26

what's called a directive which means

17:29

that member states has some wiggle room

17:31

in terms of how to implement them

17:33

and they will move from a directive to a

17:35

regulation

17:36

which basically means that those rules

17:39

will be directly transposed

17:41

into member state law this is a big deal

17:44

in the sense that there's an effort

17:47

to try to harmonize the regulatory rules

17:51

and there'll also be a

17:52

big enforcement a part of this as well

17:55

so not only will

17:57

sectors and industries and companies uh

18:00

be punished

18:01

for not um doing enough to implement

18:04

those rules but even member states

18:06

themselves and we've even seen in europe

18:08

malta

18:09

being added to the gray list and we

18:11

expect other countries added to the

18:13

the to the gray list as well the other

18:16

key provisions

18:17

that we expect to be getting more focus

18:20

is on public registries or ultimate

18:22

beneficial ownership regime

18:24

um there'll be a big focus on that in

18:26

terms of making sure that the member

18:28

state public registries are

18:29

interoperable

18:30

that the information is verified uh in

18:33

order to allow

18:33

organizations to actually understand who

18:36

they're doing business with what the

18:37

operational structures are and what the

18:39

ownership structures are

18:42

as contentious if not one of the most

18:44

contentious

18:45

uh is the fact that there will be a yet

18:47

a new

18:48

uh authority a regulatory authority that

18:51

will

18:52

be constructed from from from scratch

18:55

so the current scope

18:59

of having aml regime at the european

19:01

banking authority

19:03

will move away and in fact there will be

19:05

a completely new

19:06

regulator to actually look assess

19:10

and enforce uh eu uh aml

19:13

sort of legislation and and and progress

19:17

and then there's other issues that i'm

19:19

not gonna probably won't have time for

19:21

but there's

19:21

a number of other provisions as well the

19:23

aml legislative package is just one

19:26

this is part of a broad package

19:29

that looks at more due diligence when it

19:33

comes to

19:33

corporates and supply chain due

19:36

diligence

19:37

there's going to be an environmental

19:39

crime directive

19:40

there's going to be more focus on

19:42

electronic identification

19:44

uh more focus on kyc requirements

19:48

uh and on and on and on so we expect

19:51

that the eu themselves have really

19:53

called on themselves that they want to

19:55

be

19:55

one of the leading drivers and forces

19:57

for enhancing the current regime

20:00

and they will most likely take a very

20:02

much more active role in the

20:04

international stage

20:06

to actually engage with um with

20:09

authorities

20:10

in india in asia more broadly so you

20:13

know sub-saharan africa the middle east

20:15

and the americas as well

20:21

a quick look on industry trends and

20:23

risks in the use of technology and and

20:25

this

20:26

very much comes at the at the heel of of

20:28

our newly minted

20:30

um compliance written compliance report

20:34

uh we will make sure that that's

20:35

available to you uh within the

20:37

presentation that we have here we have

20:39

we do have a slide in the end

20:41

that has a lot of the references uh to

20:43

some of this uh

20:44

to some of this data that you make sure

20:46

that you'll have available to you

20:48

so there's a few things that we looked

20:49

at and this is part of our annual

20:52

survey that we conduct with you know

20:55

thousands of of companies uh globally

20:58

uh with you know multi-billion dollars

21:01

in revenue

21:02

to these are you know large

21:03

organizations where we try to get a

21:05

sense of you know what are the

21:06

what are the pressures what are the

21:08

risks that you're facing and i'll just

21:10

point out just a few um

21:14

it continues to be to be the fact that

21:17

the

21:17

commercial pressures uh dominate in

21:20

terms of

21:21

uh the decisions that companies make on

21:24

relationships partnerships

21:26

and business opportunities uh so 73

21:29

percent says you know the the

21:31

they're under incredible uh pressure to

21:34

increase revenue

21:36

uh and that certainly hasn't gone away

21:37

in fact that has gone up

21:39

uh since the last time that we we

21:41

conducted this survey and some of this

21:43

is understandable in terms of the

21:44

context

21:45

of the pandemic and the impact that

21:48

that's have on many many different

21:49

industries

21:52

we also see however um and this

21:55

this is a function i suspect of the

21:58

first question but where we ask you know

22:00

do you actually conduct due diligence

22:01

text due diligence checks

22:04

and majority 56 percent said they don't

22:07

um and and this is a bit of a worrying

22:09

trend and

22:10

and from our perspective is an area

22:12

that's going to increase the risks of an

22:14

organization being

22:16

either a potential sanctions being

22:18

issued

22:19

uh or or being caught in some kind of

22:22

supply chain

22:23

or sanctions levied against them

22:28

so this is quite surprising to me that

22:30

that number of organizations don't

22:32

conduct any due diligence checks

22:34

at all um 64

22:37

this is not surprising for what we hear

22:39

from many organizations

22:41

that the focus continues to be

22:44

regulatory compliance or

22:45

tick box or kickboxing exercise in terms

22:49

of do you have policy procedures and

22:50

sort of the bare minimum of being able

22:53

to demonstrate

22:54

to regulators that they have a program

22:56

and risk program in place risk and

22:57

control program in place

22:59

uh but majority of them don't focus on

23:02

on prevention

23:04

at all which is an area that we're

23:05

trying to encourage

23:07

more organizations to do um

23:11

cyber crime we mentioned that there's no

23:13

question that has become much more

23:14

difficult to contain

23:16

uh given remote working conditions that

23:18

we all live under

23:19

and cyber crime will continue to to

23:21

dominate in terms of how it affects

23:23

uh all of us and we need to sort of

23:25

watch that very carefully

23:28

bribery and corruption is still

23:29

considered to be very much commonplace

23:32

uh and that hasn't changed and that

23:34

number that's that

23:35

statistics is is in fact from a 2018

23:39

uh report uh and there's nothing that

23:41

we've heard

23:42

and that that that number has changed at

23:44

all so so this is you know another area

23:47

of concern

23:49

uh and then um we thought oh i thought

23:52

certainly that it was interesting

23:54

that that you know if you look at the

23:56

the the companies vulnerable to

23:58

financial crime you know whether you're

24:00

a private company or public company that

24:01

that in fact public companies tend to be

24:03

much more vulnerable

24:05

to some of these to some of these risks

24:07

and some of these issues

24:10

and then technology we turn our

24:12

attention to that

24:13

um there's been quite a bit

24:17

on in the last year year and a half and

24:20

in fact

24:20

accelerating investment in technology a

24:23

because of the

24:24

working conditions that we now live in

24:28

but also the recognition that in fact

24:31

technology

24:32

can really help identify financial crime

24:34

so 86 percent

24:35

uh said yes that is something that's

24:38

helped us

24:39

uh those who use technology also tend to

24:43

have

24:43

better collaboration with law

24:45

enforcement in terms of identifying the

24:47

types of criminal activity that they may

24:49

be exposed to

24:52

we've also seen a majority

24:55

you know consider that technology

24:57

improves the detection

24:58

and mitigation and they tend in fact to

25:01

invest even more

25:02

in in technology in terms of identifying

25:05

not only better screening practices

25:08

but also but also better risk typologies

25:10

as well

25:12

but we also have the issue of data

25:15

privacy

25:16

um in terms of having clarity

25:20

on how data privacy provisions affect

25:23

the

25:23

anti-money laundering provisions and

25:25

this is very much something that comes

25:27

out of the european union and the

25:28

general data protection

25:30

regulation and here we have some work to

25:33

do

25:33

in terms of understanding how

25:36

on the one hand we're trying to do more

25:38

in processing personal information

25:40

better quality information better

25:42

typologies

25:44

versus data privacy which tries to

25:46

minimize

25:47

uh data processing tries to minimize the

25:50

the ability to use

25:51

technology to make this make the fight

25:54

against

25:54

financial crime more effective less

25:57

costly

25:58

uh and also trying to address financial

26:00

exclusion

26:01

uh so there are more needs to be done in

26:03

this space we've certainly heard from

26:05

the european data protection

26:06

supervisors this is an area of focus

26:09

i suspect that this will you know commit

26:11

the four and come into discussions very

26:13

much in other regions including india

26:14

and many other

26:16

discussions as well including of course

26:18

data localization

26:20

which is another issue that we're trying

26:22

to engage with

26:24

a number of jurisdictions including

26:25

india

26:27

trying to localize the types of data

26:28

that they have within the country

26:30

uh and and for you know many companies

26:33

who are global with a global presence

26:35

uh that that becomes difficult in terms

26:37

of

26:38

managing managing that type of

26:40

restriction

26:44

and then lastly or

26:47

second to last in terms of information

26:49

sharing and we really are big believers

26:51

and how we can break down barriers

26:54

between ngos

26:57

the banking community um you know

27:00

technology companies payment services

27:02

companies and being able to share

27:03

information

27:04

in a much more effective way and while

27:07

um

27:08

historically the last few years

27:10

certainly the last five years

27:11

a lot of attention has been towards you

27:14

know

27:15

consortiums and formats like the joint

27:17

money laundering task force at the uk

27:20

have stood up public private information

27:22

sharing partnerships

27:24

that have stood up in singapore hong

27:26

kong

27:27

australia and many other jurisdictions

27:30

and those primarily have been driven by

27:32

either law enforcement to the

27:33

supervisors

27:34

bringing together a small group of banks

27:36

to try to find a way to

27:38

to share information in a more effective

27:40

way which we are big supporters of but

27:43

there's a broad

27:44

ecosystem of other organizations out

27:46

there

27:47

who have information and have data that

27:50

could be quite useful

27:52

and so these are four examples of

27:55

partnerships that we as a company have

27:57

engaged with to do exactly that

28:00

we announced the partnership with a

28:03

century

28:04

uh an organization based in washington

28:06

uh founded by george clooney and

28:09

john pendergrass really to look at

28:11

corruption in sub-saharan africa

28:13

um we've also formed a partnership with

28:16

the freedom seal

28:17

which was started by an extraordinary

28:20

woman called ronnie han

28:22

uh who in fact herself was was caught in

28:26

in child slavery uh in india

28:29

uh in a sense become a an advisor to the

28:32

un

28:32

and now the ceo of the freedom seal

28:34

which is a company

28:35

that looks at and works with companies

28:38

uh to look at their supply chain

28:41

and certifies that in fact none of the

28:43

products or services were caught

28:46

uh in in in human trafficking

28:49

and so we're working with her not only

28:51

to provide data

28:52

but also to engage with policy makers uh

28:54

to ensure that you know

28:56

we as a company and the industry are

28:58

doing our utmost

29:00

uh to tackle this issue united for

29:02

wildlife we partnered

29:04

with that organization which is a

29:06

consortium of not only

29:08

the banking sector but also the

29:10

transport sector

29:11

to look at wildlife trafficking and

29:13

illegal wildlife trafficking

29:15

it was it's run and co-founded by the

29:17

duke of cambridge

29:19

and again we are there as a data

29:22

provider but also

29:23

a an operational infrastructure provider

29:26

to ensure that there's a commonality the

29:28

data standards

29:30

are there the inclusion criteria is

29:33

standardized in order to make sure that

29:35

the best information

29:37

is really available and so we're working

29:39

with

29:40

united for wildlife uh to to scale and

29:42

to scope

29:44

uh and and to you know being able to

29:46

share that type of typologies in a more

29:48

effective way

29:49

most recently we're also now working

29:52

with the south african aml integrated

29:54

task force

29:55

which again is a collection of banks and

29:57

non-banks

29:58

to look at some very specific typologies

30:00

including wildlife trafficking

30:03

terrorism financing in other risk areas

30:06

really to being able to scale provide

30:09

the best data

30:10

available so all these are examples of

30:13

how

30:13

we can operate in a different way break

30:16

down barriers

30:17

really look at working across different

30:21

sectors

30:22

uh really to make sure that we bring the

30:24

best talent and the best capability

30:26

uh to bring to bear um and so this isn't

30:29

you know an area that i encourage

30:31

all of you for first you to contact us

30:33

if you're interested

30:34

in participating or certainly getting a

30:36

sense of what we're doing in this space

30:39

more more more technically uh and also

30:42

kind of what our plan is going forward

30:44

but you know this is an area that we're

30:46

going to increase our focus

30:48

uh in the next several years

30:52

and then lastly the global coalition so

30:55

not only are we big proponents of

30:57

of working better sharing information

30:59

better at an operational

31:01

tactical level but we also think that

31:03

it's important to engage with senior

31:05

stakeholders

31:06

um so we co-founded the global coalition

31:09

together with the world economic forum

31:11

and europol in 2018

31:14

really with a few key key objectives

31:17

the first is to raise awareness that

31:19

again financial crime is not a

31:20

compliance issue but has grave

31:23

impacts on on on the finances

31:26

infrastructure and human and societal

31:28

consequences to promote more information

31:30

more effective information sharing how

31:33

we can harness our best practices

31:35

and then really support governments and

31:37

law enforcement

31:39

and how we can bring all of our assets

31:42

to bear

31:43

what started between the three of us

31:45

between europa and world economic forum

31:47

and ourselves

31:49

has then grown quite a bit and what you

31:52

see here is really a representation of

31:54

the anti-financial crime

31:55

ecosystem so it's not just the banking

31:58

community

31:59

via the international you know finance

32:02

institute

32:03

and european banking federation but you

32:05

have also

32:06

the corporate treasurers who are there

32:08

you also have the royal united services

32:10

institute

32:10

the freedom seal as i mentioned um open

32:14

ownership mena financial crime group

32:17

uh and many other organizations as well

32:19

that represents and then you also have

32:21

fintech think crime exchange which is a

32:24

a a in consortium an organization

32:26

looking at fintech specifically

32:29

so it's a wide variety of sectors and

32:32

industries

32:33

that are now part of this and how we can

32:35

best again

32:36

harness each other's uh insight and

32:39

capability and best practice and i

32:43

encourage you to go to our website it's

32:45

quite an extraordinary collection not

32:46

only papers

32:47

but also policy positions and we and we

32:51

think it's a you know

32:52

one way in which we can effectively

32:54

engage with the policy makers to bring

32:56

them along the journey

32:58

uh in terms of what we think is

32:59

effective policy

33:01

part of that has been to engage with the

33:04

uk governments on a

33:05

data protection bill we we've

33:07

successfully amended or helped amend you

33:10

know to provide further clarity

33:12

on this issue from the uk's perspective

33:14

we've also

33:15

successfully engaged with the european

33:16

commission on its aml action plan

33:19

and we're delighted that they've adopted

33:21

many of the provisions that we

33:22

support including information sharing

33:24

partnerships including

33:26

more you know clarity around data

33:29

privacy and many other provisions as

33:31

well

33:32

and we're also engaging with the mena

33:35

region as they now are actually

33:38

considering

33:39

to establish a regional public-private

33:41

partnership

33:42

uh which we're delighted to do and and

33:45

as well some of the

33:46

sub-chapters we're delighted that john

33:48

cusack is your overall chair

33:50

uh for the next few years but we've also

33:54

brought in some of the best

33:56

and well-known leaders in this space to

33:59

do

33:59

to continue to drive some of these

34:01

initiatives we have

34:02

greta fenner who looks at

34:04

anti-corruption initiatives we have rob

34:06

wainwright

34:07

who looks at the critical question about

34:09

how we measure effectiveness

34:11

at the end of the day and then we have

34:13

three regional chapters

34:15

uh and i mentioned the mena chapter led

34:17

by ibdison lasud

34:19

to look at how we can form and promote

34:22

public private partnerships across the

34:24

region

34:25

as a whole what we expect to do in the

34:27

next year or so is turn our attention to

34:29

asia so clearly this is you know

34:32

us europe and mena chapter

34:35

focus as it's been in the last year and

34:37

a half but we will

34:38

turn our attention to asia and how we

34:40

can engage more effectively

34:42

uh with with uh with you know many

34:44

countries in the region including

34:45

including india so well you know so stay

34:47

stay tuned

34:49

so stay tuned for that i think i will

34:52

um end it there um i'm happy to

34:55

to take any any questions i hope you

34:58

found

34:59

um that helpful to give you a a

35:02

whistle-stop

35:03

tour of many of the you know the

35:06

initiatives that we're involved with but

35:08

also some of the global regulatory

35:10

uh trends um and and some of the issues

35:13

there so i will stop there hand it back

35:15

to the host and happy to take any uh

35:17

any questions

35:26

right so we have a few questions here

35:29

so i'll read out one of those video

35:33

so it sees any significant differences

35:36

in nature of financial crime and

35:38

approaches

35:39

to counter them in emerging markets as

35:41

opposed to developed markets

35:44

that's a great it's a great question so

35:46

i think fundamentally

35:48

uh no it's many of the same issues the i

35:50

guess

35:51

the difference potentially uh is the

35:54

impact

35:54

on foreign direct investment uh the

35:58

impact of

35:58

of or perceived risks by by companies

36:02

to invest and can potentially

36:06

impact our capital flows to emerging

36:08

markets

36:09

and we've heard that from from the um

36:12

from in fact many industries who wanted

36:15

to invest in south africa for instance i

36:17

was there before the pandemic

36:19

uh to talk with some of the industry

36:21

leaders who said look

36:22

che we're willing to invest 50 billion

36:24

in south africa

36:27

but we just uh don't know you know

36:30

how that regime is going to play out in

36:32

terms of the rest of the issues that

36:33

south africa has faced in terms of

36:35

perceived corruption and some of the

36:37

scandals

36:38

so i think those are you know issues to

36:40

consider and

36:42

one of the reasons why south africa of

36:44

course i've you know taken measures and

36:45

i'm sure they'll continue to do so

36:47

uh to really be seen as a safe haven for

36:50

investment

36:51

uh that will you know fuels and not only

36:54

infrastructure development

36:55

it increases taxes that enables uh you

36:58

know in more investment in

36:59

infrastructure including schools

37:00

hospitals etc so so i think i guess that

37:03

is

37:03

one component uh that is uh you know

37:06

different i guess or

37:07

a different take that impacts emerging

37:09

markets maybe more so than than

37:11

developed markets

37:16

all right so so i guess i think uh we

37:18

can take one more question from here

37:20

uh it reads how is the disparity in

37:23

accepting

37:24

and acting on effects of green crime or

37:27

environmental across regions and

37:30

countries impacting

37:31

the ability of the coalition to fight

37:34

such crimes

37:34

like how can this be addressed

37:38

one another great question so it's it's

37:41

important to note of course that

37:42

we think of green crime as yet another

37:44

example

37:46

of there's a difference between

37:48

countries being affected

37:50

where wildlife trafficking is being

37:52

extracted

37:53

you know the the countries and

37:54

jurisdictions there are distribution

37:57

uh points and countries that are then

37:59

end destinations

38:02

uh and of course you know the the the

38:04

countries most affected are the ones

38:06

uh where the animals in the in the in

38:08

the

38:09

activity is actually occurring in terms

38:11

of devastating

38:12

the wildlife the the fishing industry

38:15

uh etc um and and so you know

38:19

so i think that that is one one piece to

38:21

remember we also need to remember that

38:23

it's of course cuts across on all of the

38:25

financial sector in terms of the

38:27

the laundering of the proceeds of that

38:30

activity

38:31

but also the transport sector the

38:33

customs union

38:34

who also need to be brought in here in

38:36

terms of understanding how

38:38

you know certain trading certificates

38:40

are being exploited

38:42

um and look very much more closely in

38:44

terms of the supply chain

38:46

risks so how the coalition is going to

38:48

address this we're already

38:50

engaging with financial asset task force

38:52

on this we're all

38:53

also engaging with an organization to

38:56

look at international convention

38:58

on this which currently doesn't exist

39:00

because there needs to be laws

39:02

and consistent laws on this on this

39:04

issue in order to affect

39:05

uh implementation and enforcement uh and

39:08

we're doing it via the wildlife

39:10

trafficking convention as a beginning

39:13

step but we recognize that it's much

39:15

broader than just illegal

39:16

wildlife that encompasses a much broader

39:19

piece to that so so hopefully you know

39:22

i've gone to the

39:22

this there is a disparity in terms of

39:25

the impact there's no question about

39:26

that

39:26

in emerging markets uh tend to be the

39:29

ones most affected in terms of the

39:31

impact on its environment

39:33

the lacks of of of proceeds that are

39:35

being generated from this activity that

39:37

the government can

39:38

use for um you know green tourism and

39:42

in other you know areas um as a source

39:44

of revenue

39:50

all right that was a really insightful

39:52

session

39:53

and i believe that all of us have

39:55

certain key

39:56

takeaways to take from it

39:59

and i would like to thank you mr chase

40:01

daniels for sparing time for this highly

40:03

commendable talk

40:05

also another thank you goes out to all

40:07

our attendees who are here with us today

40:09

thank you so much everyone and we'll be

40:11

back again with the next session

40:12

please stay tuned