Dawn Fisher

This post has been provided courtesy of ICA

January 30, 2018

The importance of tone from the top and why it should not be underestimated

As firms continue to navigate the labyrinthine minefield of legislation and regulation and claw their way up the evolutionary ladder of compliance with standards that appear to have moving goal posts, ‘ tone from the top ’ has never been …

January 15, 2018

Why policy makers should shoulder responsibility for UK failings

In November 2017, Transparency International (TI) published the report Hiding in Plain Sight which further highlighted the attractiveness of UK Plc to those that wish to launder the proceeds of corruption or value of other criminal origin. On the face …

December 11, 2017

Why KYC is like building a house

Whilst the CDD process can be considered as a process with inputs and outputs I would like to put forward another way to think about this subject area. As my students know, I love a good analogy and the parallels …

July 6, 2017

Money Laundering Regulations 2017

On Monday 26 June 2017, by the skin of its teeth, the UK enacted the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs 2017). Dragging its heels, somewhat unusually for UK Plc, …

April 29, 2015

Banks – between a rock and a hard place?

Yesterday the Financial Conduct Authority in the UK released a statement of their expectations of Banks’ management of money laundering risk: Where a bank does not believe that it can manage the money laundering risk associated with a business relationship …

April 13, 2015

A Call for Information, but are we asking the right questions?

In the UK Anti-Corruption Plan, published on 18 December 2014, the Government committed to carrying out a review of the suspicious activity reports (SARs) regime contained in the Proceeds of Crime Act 2002 (PoCA) and the Terrorism Act 2000 by …

February 26, 2015

5 ways to maximise your workshop experience

For those of you who are based in a country where we offer workshops as part of your course, here are a few hints and tips on how you can maximise your workshop experience. The workshop pre-reading. This should be …

January 27, 2015

Trade-based laundering – is automation the key?

Having just spent the last week in Singapore training on the risks of financial crime in trade finance, I read with interest a report by PwC on addressing money laundering risk in the trade finance system. Whilst this report quite …