What's your source? Wolfsberg, Wealth and Funds

We're back for Season 5! 

We begin with a look at the new Wolfsberg guidance around Source of Wealth (SoW) and Source of Funds (SoF). Whilst we're broadly very supportive, there are a couple of elements about which we're not quite so enthusiastic.

Transcript

Ray: Hello, and welcome to this third episode of season five of The Dark Money Files in which we shine a light into a murky world. I am Ray Blake and with me is my cohost friend and business partner. Graham Barrow. Hello Graham.

Graham:  Hi Ray. 

Ray: I don't know if you realize Graham, but it's only a couple of weeks now until our conference, The Dark Money conference, runs. 

Graham: Yeah, I know Ray. We've been working closely with our partners at Fscom to get the final details nailed down. And if I'm honest, I'm getting really quite excited now. 

Ray: Yeah, me too. I thought this might be the right time to outline what we'll be covering, who will be speaking, and what we think the conference might achieve.

Graham: That sounds like a really good idea. And perhaps we might in the process, encourage some more of our listeners to make the decision to come along and join us. 

Ray: That will be nice. Graham. Whenever I meet listeners, I'm fascinated by their stories and it gives me a real sense of community that in my time, as an independent practitioner has been in short supply, sometimes 

Graham: I think you're absolutely right Ray. And that's something we really want to build on at the conference. 

Ray: Yes. So. Let's start with how the idea of a conference arose, shall we? Because I'm almost ashamed to say it wasn't our idea. 

Graham: No, it wasn't. Late last year we were at a meeting in London with Phil Creed and Jamie Cook of fscom talking about the podcast and our plans for the future.

It was them who suggested the idea. And as soon as they did it, it was suddenly such an obvious step. 

Ray: I think it was me Graham, who pointed out that we had no idea how to run a conference. 

Graham: Well, that’s right, but I could just as equally have said that, at least I think I could have done, but I was far too busy getting excited about the idea to think about such practical things. And actually it was fine because Phil and Jamie immediately said “We can help you.”

Ray: And they've been a fantastic partner in the endeavor.

Graham: Oh, they really, really have. So fast forward to March this year when Phil met us at a very impressive venue in Central London. He'd been identifying possible venues for the conference and this particular one was very much top of our list. 

Ray: It was, and we had a tour of the facilities, which were absolutely ideal for what we were planning. There was exhibitor space, a huge informal milling area and little meeting alcoves as well as a simply magnificent auditorium.

Graham: Suddenly, I think we all had a very clear vision of what this conference would look and feel like and we were very, very excited.

Ray: We were. And at the same time, we'd all been thinking about who we might get to speak and appear on panels. And it seemed as though everyone we spoke to was really keen to get involved 

Graham: And then, as March progressed, it became clear that there was going to be a major impediments to our plans. Just a couple of weeks after booking the venue we were in lockdown. 

Ray: We were, but then I'm not sure whose idea it was initially, but it was an audacious one;  we'd run the conference as originally planned, but entirely online. 

Graham: Mm. And this was before Zoom and Teams had become quite the fixture of our working lives that they are now. We weren't quite sure we knew how it would work only that we were determined to see if it could.

Ray: So here we are six months later, ready to kick off what is even more of a first for us than we already thought it was going to be. 

Graham: Yeah. So let's give people the short version of what the conference is about and then walk through it in a bit more detail. Shall we? 

Ray: Yeah, let's do that. We're running over three half days, all mornings, on the 23rd, 24th and 25th of September.

Graham: That's a Wednesday, Thursday and Friday morning. 

Ray: And each day has a loose theme. Day ones is global response, and we'll be focusing on the global response to financial crime, looking beyond the national frameworks, to look for a joined up approach across the world. 

Graham: And we've got some great speakers helping us to do that.

We kick off with the two of us introducing author and freelance journalist Oliver Bullough great friend of the dark money files who is always compelling to listen too. 

Ray: He absolutely is. Then we've got our first panel discussion, which we're calling organized crime, organized response, looking at how we can be more joined up in investigations to expose more fraud, corruption, and other financial crime.

Graham: And our panelists, and get this, Paul Radu, who is the director and co-founder, of the Organized Crime and Corruption Reporting Project. We have a Federica Taccogna, who's a partner at FTI Consulting and then a still yet to be determined, but senior representative from Transparency International, it's going to be a really interesting discussion.

Ray: It absolutely is. After a break, we go into a second panel, national frameworks versus global crime 

Graham: And we have got four panelists collectively discussing the frustrating reality that crime crosses borders quite freely, while law enforcement halts at the border 

Ray: And who are they Graham? 

Graham: Well Ray, also exciting, we've got Neil Wiley who's the head of the International Sanctions Program at UK Finance. We've got Jesse Spiro the head of policy and regulatory affairs at Chainalysis. Matthew Collin, who's a David M Rubenstein fellow at the Brookings institute in Washington and Margot Gibbs an incredibly engaging investigative journalist who works at Finance Uncovered.

Ray: That's really going to be worth listening to. As with all our panels, there's an open Q and A, so people can raise their own questions for panelists too. 

Graham: That's right. And then towards the end of the morning, before we move into the networking section, we have our first keynote speech. 

Ray: We're delighted that we've secured Transparency International's chief executive Daniel Bruce. 

Graham: Which is amazing Ray. 

Ray: And that's just day one, Graham. 

Graham: Yeah I know! So let's move on to the Thursday. Day two’s overall topic is processes and outcome. 

Ray: We're interested on day two in the balance between the processes that regulators firms and law enforcement pursue and the actual financial crime outcomes.

Graham: Yeah, it's a fascinating discussion Ray. Who have we got helping us there then? 

Ray: Well, it kicks off with you and me Graham, and we'll be introducing the days first guest, who is Josie Preston head of anti-money laundering and MLRO at the Ritz club. 

Graham: The Ritz club. Come on. I am so glad we've got Josie on board, Ray?

Her role means she has a very different view of things from most MLRO. 

Ray: And she has some fantastic stories to share too. 

Graham: She certainly does. And then day two’s first panel has a rather lengthy title, which is “is the advancement in technology improving manual processes rather than advancing our approach?”

Ray: And I can't think of a more relevant question in the financial crime technology field right now.

Who's going to be helping us answer it. Graham? 

Graham: Well, Ray. We've got Marta Lia Requeijo, who's the senior financial crime and compliance director at Clearbank. We have Livia Benisty who's the global head of business, AML at Banking Circle. We have our good friend, Rachel Woolley, director of financial crime at Fenergo and Matthew Leaney who's the chief revenue officer at Silent Eight

Ray: I can't wait to hear what they've got to say. And that's followed by our second panel of the day, “too big to fail or too broken to fix?”

Graham: Good title. 

Ray: Uh, we had to clean it up a bit from the first draft Graham. 

Graham: Yes, Ray, I remember. This discussion will centre on fines against big institutions and what they're achieving, and what might be coming next.

Then what all firms need to know about the regulatory agenda for 2021 

Ray: Sounds useful. Who've we got to help?

Graham: Well, we've got Priya Giuliani managing director of financial crime risk management from Promontory. We've got Blair Halliday the chief compliance officer for Europe at Gemini and Katarina Cook, head of financial crime prevention of Brewin Dolphin.

Ray: That's a great line-up, Graham, how are we ending that day? 

Graham: We've got a great keynote from our friend, Rebecca Lee, the Chief Impact Officer at OpenCorporates. Now of course, OpenCorporates, brilliantly unites processes with outcomes. So of course it's a great way to end the day and we'll be hearing from her about some of the challenges they've had to overcome and the fights they continue to wage on our behalf.

Ray: Yeah, quite so. We must remember to come back later to the OpenCorporates workshop we've helped to produce for the conference too. 

Graham: Yes, we must. Shall we cover day three first?

Ray: Uh, yes, day three, we're calling victims and villains. And we want to think about how the law treats both those sets of people, as well as how the industry does.

Graham: And we're kicking things off again. You and me and helping us this time will be David Balson. Who's the director of intelligence at Ripjar. 

Ray: He's a fascinating chap, a former spook of course from GCHQ. 

Graham: Oh, are we allowed to say that Ray? 

Ray: Well, if we're not, I'm sure people won't be hearing this podcast episode Graham.

Graham: Fair point 

Ray: Our first panel poses, a big question, punishment or salvation?

Graham: That's a great question, isn't it? In other words, is our legislative and regulatory framework there to punish the criminals or save the victims. 

Ray: So who's going to throw some light on that issue for us. 

Graham: Well, we've got Frederic Pierson from Europol. We have Ben Keith, a leading barrister with a highly relevant client list, Patrick Lordan, who's the head of the Garda National Economic Crime Bureau in Ireland, and DeQuincy Bailey who's an investigation. Officer in HMRC’s Fraud Investigation Service and Organized Crime Operations. 

Ray: I don't think we could have found four people more qualified to discuss this. 

Graham: Do you know Ray, neither do I. What's the second panel discussion on the last day.

Ray: It's about how technology can benefit the victims of financial crime. 

Graham: Now that is a very interesting topic, and we've got some top panellists to help us address it. There is, Dominique Mac, managing director of risk and compliance, managed services at Promontory. There's the lovely Joe Jenkins global compliance director at Railsbank and Aidan Larkin, and anyone who's ever seen Aidan do a presentation will recognize that name instantly. And he's the founder of Asset Reality, LTD.

Ray:  Fabulous. It's an important discussion. And one that I don't think gets much bandwidth at the moment. 

Graham: I could not agree more. Ray. 

Ray: So how are we going to finish day three and indeed the conference. 

Graham: Well, not in a way people might expect actually, well, no, our keynote speakers are Matthew Caruana Galizia and Jonathan Price QC. They will be talking about Matthew's mother, Daphne, the contribution she made to the anti financial crime community and the terrible price that she paid for that. 

Ray: Uh, yes. And about the plans for the foundation established in her name. 

Graham: Yeah, the Daphne Caruana Galizia foundation. It will be a memorable end to the conference, I suspect. 

Ray: But of course it won't be the end. Will it? 

Graham: No. Ray, a conference ticket covers attendance on the three days, of course, but you also get ongoing access to the conference discussions, networking and other materials. 

Ray: And among that other material, you'll find a set of master class workshops. Our speakers have contributed on key topics we think people will find useful and interesting. 

Graham: Yeah. So let's run through some of those workshops quickly, shall we? We're expecting to have half a dozen or so overall, but perhaps we could focus on the three that we've been working on personally this week. 

Ray: Let's. We've already mentioned the OpenCorporates one, and this offers a primer on open data and how OpenCorporate’s tools can support different people and organizations in the fight against financial crime.

Graham: Hmm, we were involved in putting this one together and you'll see in here, how we use the OpenCorporate service in an actual investigation and how it enabled us to make links we could not have made any other way. 

Ray: Yup. After viewing the workshop, you'll be ready to get started with using OpenCorporates to support your own work.

Graham: Fantastic. And then we worked with David Balson to put one together called Hidden in Plain View, understanding the changing impact and value of open source news data. 

Ray: Yes. Covering why modern intelligence has little to do with the popular perception of spies and spying, the frontiers of open source intelligence, the issues of bias fabrication, language, localism and filtering, and how these challenges are being addressed with new advances in technology, reaching for the Holy Grail of false positive reduction. 

Graham: Wow. Yeah. And we already know that it contains some just amazing stories. And it will help you challenge some of the methods and assumptions behind due diligence investigations as they are typically conducted now.

Ray: Yeah. Fantastic stories. I'll never trust a cat again.

Graham: Or indeed a dragon fly.

Ray: Yeah. And it will help you think about systems that might make a positive difference, both to the fight against financial crime and the ability of banks and other institutions to make surer and quicker new business approvals.

Graham: And of course, you and I did one all about the C word didn't we. 

Ray: Ah, yes. A Dark Money Files illustrated special on COVID and money laundering. 

Graham: It looks at the additional challenges that COVID brings to the AML world and some of the ways that money laundering and pandemics behave similarly. We end with a checklist of potential measures to address these new threats.

Ray: And I know there are other workshops in construction right now, aren't there?

Graham: Yeah. Including one I'm particularly looking forward to seeing, on artificial intelligence and how to raise your use of it with the regulator. 

Ray: Yes. I'm waiting to see that one too. 

Graham: Look, we would love to welcome as many of you as possible to the conference this month.

Ray: I know a number of you already have tickets, but there are more available. 

Graham: Hmm. One of the benefits of the online hosting is that we aren't limited to the number of people we can get into a building. So there is plenty of room for all of you. 

Ray: Yes, there is. You can check all the details at the conference website, which is https://darkmoneyconf.com/

Graham: you can look at the speaker bio's, see a full agenda and learn what else is provided, and then decide if you want to buy a ticket. 

Ray: You can buy a ticket for any individual day or days or a full ticket for the whole thing. 

Graham: And they're not very expensive are they Ray?

Ray: Not really. No. 

Graham: Good. And obviously we hope that you will.

Ray: We do. What's next on the podcast Graham? 

Graham: Well Ray, I think we do need to focus on the conference now. So I imagine our next episode will be a review of the conference

Ray: I'm looking forward to it.