CW Compliance

📢 Update on FCA's Guidance for Politically Exposed Persons (PEPs) Last week, the consultation for the FCA’s proposed amendments to the Guidance on the treatment of Politically Exposed Persons (PEPs) (GC24/4) officially closed. With these changes initially outlined in July, our consultant, Paolo Collauto, has analysed the potential impacts, particularly as they relate to recent legislative shifts in financial crime compliance. 📄 Read Paolo’s full analysis below to explore how these changes may shape the future of PEP risk assessments and influence compliance strategies across the sector. #FCA #PEP #Compliance #FinancialCrime #AML #RegulatoryUpdates #CWCompliance

📢 Update on FCA's Guidance for Politically Exposed Persons (PEPs) Last week, the consultation for the FCA’s proposed amendments to the Guidance on the treatment of Politically Exposed Persons (PEPs) (GC24/4) officially closed. With these changes initially outlined in July, our consultant, Paolo Collauto, has analysed the potential impacts, particularly as they relate to recent legislative shifts in financial crime compliance. 📄 Read Paolo’s full analysis below to explore how these changes may shape the future of PEP risk assessments and influence compliance strategies across the sector. #FCA #PEP #Compliance #FinancialCrime #AML #RegulatoryUpdates #CWCompliance

📜 💡 Before Mercore, there was CW Compliance... Mercore was borne out of CW Compliance's global compliance expertise - this has been instrumental in Mercore's ability to provide trade finance solutions, making finance more accessible to businesses of all sizes around the globe - with a particular focus on financing SME's. The African Export-Import Bank (Afreximbank) Compliance Forum offered valuable insights into the intersection of compliance and trade, and provided a fantastic opportunity for knowledge sharing. We believe that collaboration and mutual understanding are key to driving future success in this space. #TradeFinance #Compliance #SMEs #GlobalFinance #Afreximbank #Mercore

🇸🇳🏛 African Export-Import Bank (Afreximbank) Compliance Forum 2024, Dakar, Senegal Two of our consultants, Galajo Bah, MSc, FCCA, ACFS, CAMS, ICA and Sam Riches have just returned from the African Export-Import Bank (Afreximbank) Compliance Forum 2024 in Dakar, where they had the opportunity to engage with influential figures across Africa’s financial landscape, including leading banks, EMIs, regulators, government agencies, and technology providers. The forum provided an important platform to explore Compliance and Trade in Africa, with a particular focus on FATF Recommendation 24 and its role in identifying Ultimate Beneficial Owners (UBOs) and facilitating trade. Key discussions highlighted challenges such as: 📑 Readiness of national registers 👩🏿⚖️ Effective regulatory action ✅ Ensuring data quality 🌍 Adapting global standards to local contexts. We were inspired by the thoughtful discussions and shared commitment to addressing these important issues. Special thanks to Afreximbank, including Idrissa DIOP (Compliance Director) and Fungai Nyamahowa (Manager, Financial Crime Compliance), for their leadership in these efforts. At CW Compliance, we’re dedicated to collaborating with financial institutions across the continent to navigate compliance challenges. Our sister company, Mercore, shares this commitment in its efforts to expand access to finance in markets that have historically been underserved, fostering opportunities for growth and supporting financial inclusion across the region. We’re excited about the future of compliance and trade in Africa. See the attached video for some highlights from the event! 📷 #ACF2024 #Compliance #TradeFinance #FATF #UBO #Africa #FinancialCrime #CWCompliance #Afreximbank #FIs

📰 🚨 Our latest Newsletter is out! In this months edition we're covering a number of topics from last month, including the latest updates in the Maltese PEP bribery case, the FCA charges against social media influencers and our Think Piece this month on "Crypto Mixers". Enjoy! #AML #FinCrime #AntiBribery #FCA

🚨 🇬🇧 💷 Nearly 40% of Dirty Money Laundered Through London and UK Territories The UK's deputy foreign secretary Andrew Mitchell has announced that an estimated 40% of global money laundering flows through the City of London and UK Crown Dependencies like the Cayman Islands and British Virgin Islands. Mitchell stated these territories have not done enough to implement public registers of beneficial ownership as required by 2016 UK legislation. He warned that if they want to continue using the UK flag and monarch, they must accept British values against allowing inflows of dirty money, often stolen from Africa. Under David Cameron as the new Foreign Secretary, Mitchell predicted there will be greater emphasis on forcing the Overseas Territories to introduce public ownership registers to crack down on this flow of illicit funds. While some territories have cited European court rulings to restrict public access, Mitchell emphasised they are not subject to EU laws. The UK passed a law in 2018 requiring a draft order by 2020 to impose beneficial ownership registers, after a Tory backbench revolt that Mitchell supported. The Cayman Islands has pledged enhanced public access by late 2024 only for legitimate anti-money laundering purposes. However, delays by Dependencies like BVI in implementing proper transparency continue to allow vast sums of tainted money to be laundered through the UK financial system. With the government forcing overseas dependencies to implement public beneficial ownership registers, firms must urgently enhance their defenses against illicit finance. With our compliance expertise, we are well-equipped to support organisations in getting ahead of the regulatory reforms on beneficial ownership transparency. Contact us to learn how we can help your firm enhance its AML controls and align with these requirements. 📧 compliance@campionwillcocks.co.uk #MoneyLaundering #FinancialCrime #AML #TransparencyRegister #KYC https://lnkd.in/dpGR4Ahb

📰 🏛 Industry News The 33rd session of the United Nations Commission on Crime Prevention and Criminal Justice (CCPCJ) opened in Vienna yesterday (13th May 2024), with member states and stakeholders deliberating on combating organised crime, corruption, terrorism, and other criminal activities through enhanced international cooperation in areas like extradition, mutual legal assistance, and asset recovery. As the UN's principal policymaking body on crime prevention and criminal justice, the CCPCJ plays a pivotal role in advancing the Sustainable Development Goal 16 (SDG 16) on promoting peace, justice, and strong institutions. The session highlighted the importance of cross-border collaboration at every stage, from intelligence sharing to law enforcement cooperation and judicial assistance, to tackle transnational crimes effectively. A special event was held to discuss preparations for the upcoming 15th UN Congress on Crime Prevention and Criminal Justice, emphasising its role in achieving the 2030 Agenda for Sustainable Development, especially SDG 16. The event explored good practices, lessons learned from previous Congresses, and key elements like accelerating crime prevention, protecting people and the planet, and leveraging the digital age. With its broad mandate covering areas like reducing violence, trafficking, illicit financial flows, and corruption, the CCPCJ is uniquely positioned to support the achievement of SDG 16 through promoting action in the criminal justice domain. Follow this link to read more: https://lnkd.in/ebFy2bdS #UN #CCPCJ2024 #CrimePrevention #RuleOfLaw #SDG16 #InternationalCooperation

📰 🔊 Our latest newsletter is out now! We're reviewing industry and regulatory news and updates from April, including the Panama Papers trial and the of the EUs adoption of the AML reform package. Our Think Piece this month covers the National Crime Agency (NCA) alert on #Sextortion and what #FinCrime professionals can do to help. We hope you enjoy the read. And, as always, we welcome your feedback. #PanamaPapers #crowdfunding #EUAML #AML #CDD #NCA

📰 🇲🇹 Industry News With global elections seeing record voter turnout this year, politically exposed persons (PEPs) remain a high priority for financial institutions' compliance efforts. Maltese Deputy PM and European Commissioner nominee Chris Fearne potentially faces charges related to a controversial 2015 hospitals concession deal - another reminder of the risks posed by PEPs. An inquiry found the deal, which handed lucrative contracts to an inexperienced company that later sold out, appeared "fraudulent" with "collusion" by senior Maltese officials. Former Prime Minister Joseph Muscat, his ex-chief of staff, and a former minister were also named in a money laundering probe tied to this deal. Despite resigning in 2019 amid protests over ties to a journalist's murder suspect, Muscat remains politically influential in Malta and has attacked the judiciary's findings as an "establishment plot" ahead of European elections. This case underscores the persistent risks and the broader challenges of upholding EU values and integration when PEP activity is left unchecked. As PEPs continue making headlines globally, this is a crucial reminder for financial institutions to apply rigorous due diligence to all PEP relationships and transactions. Ongoing monitoring, document trail audits, and proactive investigative measures are essential to mitigate the risks PEPs pose to the financial system's integrity. If your firm needs assistance or advice with PEP compliance, please reach out to us for support. 📧 compliance@campionwillcocks.co.uk #PEPs #AML #RegulatoryCompliance #FinancialCrimeRisks #DueDiligence #FinancialIntegrity #EUAML #KYC #RiskManagement #FinancialCrime #

🏛 🚨 Regulatory Update HM Treasury has today released its Anti-money laundering and counter-terrorist financing: Supervision Report: 2022-23. The annual report seeks to provide an overview of their "second line" - the supervisory bodies who work to ensure that regulated firms have effective controls in place - and their efforts to combat money laundering and terrorist financing activities through supervision and enforcement actions. We've summarised the key points regarding the #FCA findings below, which includes references to #Crypto which remains and ongoing concern (see our newsletter from last month for a Think Piece on Crypto regulation). It is well worth reviewing the report in respect of the other supervisory bodies, including #HMRC and the Gambling Commision, and the Case Studies which provide deeper context and understanding through examples of effective use of surpervisory powers. FCA Findings - Summary ▶ The FCA employed 52.8 full-time financial crime specialists dedicated to AML/CTF supervision, with 15.8 specifically for crypto-asset businesses. ▶ The FCA identified retail banking, wholesale banking, wealth management, and crypto-asset firms as particularly vulnerable to financial crime and posing the greatest money laundering risk in 2022-23. ▶ The FCA conducted 231 desk-based reviews and 7 onsite visits in 2022-23, with a focus on high-risk firms. They also opened 375 additional financial crime and sanctions cases. ▶ The FCA adopted a new data-led approach, including the REP-CRIM survey, data analytics tools (Outliers/PAMLP), modular assessments (MAPP), and focused supervisory interventions (FSI). ▶ Common issues of non-compliance identified by the FCA included inadequate risk assessments, insufficient enhanced due diligence, ineffective compliance monitoring, inadequate resources and training, and poor documentation. ▶ The FCA became the AML supervisor for crypto-asset businesses in January 2020 and applied a robust assessment process, rejecting many firms with weak controls. ▶ In response to the Russia-Ukraine conflict, the FCA diverted resources to mitigate sanctions risks, conducting assessments and developing supervisory processes for sanctions compliance. ▶ The FCA sent communications to over 10,000 firms considered higher risk for sanctions evasion and rolled out an automated sanctions screening testing tool. https://lnkd.in/e5JvEDrK #HMTreasury #AML #CFT #RegulatoryUpdate #MoneyLaunderingRisks #CryptoRisks #FCA #HMRC #GamblingCommission #Sanctions