Recently, we conducted a poll of ICA members and the wider compliance community on sustainability and the role compliance has in addressing it. The results were not only revealing, but pointed to a potential new direction for compliance as its responsibilities expand.
This blog series will explore sensitive questions around whistleblowing. It will consider the social and individual processes that surround deviant corporate behaviour and why these are strong barriers to ‘speaking up’. It will also ask how we can bring those barriers down. A field operation plan for whistle-blowers will also be built, sharing techniques that individuals can adopt to assist them in the face of corporate misdemeanours.....More
Why every compliance professional needs to know how to protect customers’ monies and assets – and why they should encourage others to do the same.
What could you be doing to file more effective suspicious activity reports (SARs)?
A recent roundtable, sponsored by Wolters Kluwer and organised by ICA, looked at the importance of balancing machine learning (ML) and artificial intelligence (AI) with human intelligence and intervention.....More
An effective GRC practitioner must face problems rather than avoid them, hold to principles when it is easier to dodge them and challenge commonly accepted beliefs when needed. What psychological research tells us is that these qualities do not come naturally to us as humans.
We are already seeing signs that the 2020s will be vastly different from the 2010s and unrecognisable in many ways from, say, the 1980s. Back then, a ‘job for life’ was a reality and a career within a single profession or trade, perhaps even with the same employer was common place. These days, rather than seek a job for life, Generation Z are more likely to question how they can leverage their value now and start their own business or, at least, a side hustle. This article will explore these differences and look at how compliance could be reimagined in the future and who is best suited for a role within this burgeoning industry.....More
A recent roundtable on best practice for risk assessment, sponsored by OneTrust and organised by ICA, uncovered some fascinating insight from those on the front line of compliance.
This insight article will consider what global compliance looks like at a local level. It will also examine how different regions understand and adapt definitions of compliance to their own purposes, and the consequences of this for businesses.
Compliance teams need to think and act more holistically, strategically and embrace innovation – to ‘design in’ rather than ‘bolt on.’ It’s vital they play their part in unlocking synergy and adopt a mindset that values reflection.
Curiosity is not often seen as an attractive trait: as the saying goes ‘curiosity killed the cat’. But for compliance professionals, I would argue that it is a key skill we need to improve both personally and professionally, and in order to protect our firms from risk.....More
Over the last five years, there has been a significant shift in the sanctions world, from traditional jurisdictional and list-based sanctions to those that are more nuanced and thematic.
There are plenty of unanswered questions following the recent meltdown of family office Archegos Capital Management—and plenty of compliance lessons to be learned.
In a rapidly changing digital world, thinking around compliance needs reframing. The question today is whether compliance can keep up in world moving faster than any had thought possible....More
We are pleased to announce the launch of ICA’s Monthly News Chat, a brief and informative video series, providing a rundown of key topics trending that month.
When a compliance professional perceives their pay package may be reduced as a result of their actions, there is a risk of biased decisions....More
A global panel of experts with law firm Gibson Dunn share insights around recent anti-corruption developments in some of the world’s largest regions, including China, India, Latin America, and Africa.
What is the real value and benefit of training to the modern compliance professional?
The UK has completed the process of leaving the European Union. This article is a follow up to a previous piece where the complicated relationship between sanctions and the UK’s transition from the EU was assessed. Here we will look at the reality of post-transition UK sanctions and the new sanctions landscape in the UK.....More
As a global organisation, we understand that diversity and inclusion is different around the world - the challenges faced by different groups vary significantly.
What is the role of the HR function in driving D&I, and the importance of compliance management in overseeing changes in organisational behaviour and practices?
As the UK leaves the EU there are some areas of legislation that will diverge from one another, sanctions is one of these. The UK adheres to both UN and EU legislation and once it leaves the EU framework it will be responsible for it’s own fate. With the transition period coming to an end, this piece will look at how the UK is preparing to strike its own path and the complexities involved in future relationships with the EU and other countries.....More
How security, risk management, compliance, and audit professionals can start using this evolving technology in everyday activities
Experts offer best practices on how to ensure your D&I policies, training, and resources are sufficient at this social and cultural inflection point.
To change perceptions on training, a culture shift is needed to demonstrate to employees that training can not only be engaging but actually useful, enhancing their ability to carry out their role. How do you get employees to embrace training and, more importantly, use the knowledge and skills from this training in their daily roles?....More
As remote work suddenly became commonplace during COVID-19, an existing information challenge was greatly magnified: how to record online data sources that are difficult to monitor and manage.
This free to download e-book by Galvanize explains how technology can improve your regulatory and policy compliance....More
Automation and artificial intelligence (AI) are set to pose a unique challenge to the future workplace, including the compliance profession. How should compliance respond to such innovation?
Today, more than ever before, compliance professionals must contend with myriad challenges including rapid digitisation, technological disruption, fast-moving regulatory change, and new forms of risk. As a result, their capabilities are coming under increased scrutiny, with many asking the question: how does the skillset of the modern compliance professional need to evolve for the function to be successful?
The three lines of defence model is an important way of managing risk within a business. If you're working in the second line and have recently moved to the first line, you could find this a daunting experience.....More
1MDB, the financial scandal linked to prominent figures in Malaysia, is under investigation in a number of countries, and those alleged to have committed crimes are slowly being brought to justice.
On International Women’s Day, we caught up with Angelia Lee, Sandra Horma and Alice Chen, who were on a 'women in compliance' panel at the 2nd Annual APAC Conference last year. They share their great insights, experiences and advice for other women in the compliance industry.....More
Sanctions are a really useful tool in global politics, but they aren’t perfect. This insight article explores four ways that sanctions could be improved and made even more effective in their design and implementation.
The role of the compliance officer has changed. Typical compliance responsibilities – interpreting regulations and legislation, creating policies and advising various business areas of their compliance requirements – remain fundamental, but as compliance develops so do the requirements for a compliance officer.
Facebook’s tough few years symbolises the danger of underestimating risk. Compliance professionals can learn from the company’s mistakes to protect their own firms in an unpredictable environment in 2020.....More
The compliance career path has never been a straight line. It’s not like medicine, for example, where you know early on you’re going to be spending a lot of time and money learning to become a doctor. And once you become one, you spend the rest of your working days practising medicine.
The UK’s data regulator, the Information Commissioner’s Office (ICO), has issued guidance to help organisations explain their use of — and reliance on — artificial intelligence (AI) in decision making and how such technology might impact the public.....More
Download your free copy of Dun & Bradstreet's latest e-book ‘Busting The Myths That Make Third-Party Risk Management More Painful’ published in association with ICA
Compliance professionals employed in SRA-authorised law firms should be busy preparing to support their colleagues to make a safe and appropriate transition.....More
‘Vulnerable Customers’ is not a topic you can avoid if you are a compliance professional in the retail sector. While the UK may be leading in the implementation of new requirements, many other jurisdictions are incorporating or considering the principles involved. These principles are pretty much incontrovertible and so there is inevitable pressure and momentum behind development of this area.
Fresh legislative initiatives and large scandals are thrusting whistleblowing on to the corporate agenda. However, how companies approach internal whistleblowing arrangements varies significantly across Europe. This is according to the Whistleblowing Report 2019 published by the University of Applied Sciences HTW Chur in Switzerland and EQS Group.....More
Compliance culture, especially in financial services, is a really important element that can impact on the wider cultural challenges that a firm could face.
Virtual currencies, cybercrime and Trumponomics, to name just a few, present interesting dilemmas: to what extent should we be conversant in these areas in order to fully understand the financial crime risks associated with them?....More
Ten years ago, the Middle East was a different place to the one that we see today. You only have to look at a picture of the Dubai skyline in 2008 and compare it to the current one to appreciate the aesthetic changes that have taken place. But it has not only changed aesthetically: the regulatory progress in the region’s financial sector has been equally discernable.
The new Transparency International Corruption Perceptions Index (CPI) has been released and you can see the results here. The Index is used in many financial crime models and is a highly regarded tool for geographic risk insight.....More
Despite significant investment in compliance, we still see incidents where things go wrong. In many cases the root cause is the wrong culture and values. How do you drive the right culture across your organisation? How do you ensure everyone is accountable for compliance matters? Below we provide some tips to help support a successful compliance ‘change programme’.
Carlos Ghosn has his own comic book, The True Story of Carlos Ghosn. It ran as a strip in the manga Big Comic Superior in Japan in 2001, before being published as a book the following year. In a country obsessed with comic books, Ghosn having his own should give you an idea of the reverence in which he is held for reviving the ailing carmaker Nissan after his arrival in 1999.....More
Collecting all the information required to manage your compliance programme is not only time consuming but can be costly. So, how exactly do we propose to make this less painful?....More
Integrity is hard to pin down. We know that some people have it and some people don’t, but in terms of one’s character, true integrity, particularly in adults, is fixed.
Have you ever wondered which skills and attributes are useful when working in compliance? If you currently work in compliance, have you considered how your own skills measure up?
You could be forgiven for thinking that the Senior Managers and Certification Regime (SMCR) is old news – been there, done that, move on to the next thing. This could well be the case if you work in the banking sector, but for the rest of the financial services fraternity it is most definitely up there on the ‘things to do’ list.....More
It seems not a day goes by at the moment without some mention of Bitcoin, cybercrime, political machinations, Brexit, global instability or the drivers of radicalisation, amongst other things. On top of this, there are even TV dramas about most of these subjects.
It struck me that the compliance department has certain parallels with the Ministry of Magic from J.K. Rowling´s Harry Potter series. Both are often misunderstood, mysterious, ‘secretly’ structured but at the same time necessary and important.....More
Hooray! I’m a winner! I won £412,000 on the Pakistan Prize Bond Draw. And I didn’t just win it once. I won it 123 times. Yes – you read that correctly. I won it 123 times. Fancy that eh? What an incredible run of luck. Now pause, if you haven’t already. That’s as likely as winning the UK National Lottery jackpot 40 weeks running…
Since 2008, the UN has held its day in honour and promotion of democracy on 15 September. For a cluster of nations across Latin America, this is a date that holds a special reverence, marking their independence from colonial rule: Guatemala, El Salvador, Honduras, Nicaragua and Costa Rica all celebrate their independence day on 15 September (with Mexico’s the following day, and Chile’s three days later).
Since 2008, the UN has held its day in honour and promotion of democracy on 15 September. For a cluster of nations across Latin America, this is a date that holds a special reverence, marking their independence from colonial rule: Guatemala, El Salvador, Honduras, Nicaragua and Costa Rica all celebrate their independence day on 15 September (with Mexico’s the following day, and Chile’s three days later).....More
Technological innovation is ceaselessly impacting on many key sectors of our lives, and the financial industry is not immune to it. European institutions are aware that technology-enabled and technology-supported financial services (FinTech) represents a great opportunity for the financial industry.
Distributed ledger technology (DLT) – of which blockchain is one particular type – is a decentralised database. This means that instead of records being held by one trusted entity that is the true source of the information (which is how many databases operate at the moment in the form of a ‘centralised ledger’), a group of peers maintain a shared database. Therefore, the consensus of the group is the record: there is no single trusted source.
This weekend sees the annual English FA Cup Final. It’s been previously reported that this football match can attract half a billion viewers from across the world. Chelsea won the English Premier League this season. This was widely lauded as being down to a switch to a 3-5-3 formation in the early autumn. Arsenal have often utilized 4-3-3 formation. The ‘3 lines’ seems to dovetail rather nicely with the ‘3 lines of defence’ mode (3LOD), which is widely used in regulated firms to provide a systematic approach to risk management. Let’s explore that a bit further so we can draw out the similarities.....More
Panama, Brazil, Afghanistan, China, Malaysia, Pakistan, Ukraine, Angola, South Africa. Examples of corruption cases abound beyond the limits of European geography. A cursory look at the Transparency International Corruption Perception Index shows plenty of low-ranking jurisdictions, many situated at a substantial distance from continental Europe. Does this mean that European companies, executives, regulators and prosecutors can sit back, head early for the beaches of the Mediterranean this summer and leave their international counterparts to manage these anti-corruption risks far from Madrid, Paris, Rome and other EU capitals? Clearly, the answer is ‘no’.
Fifa, football's world governing body responsible for promoting and protecting the sport, has done more damage to the reputation of the game than any other organisation or individual.
Listen to Sally Scutt, ICA Strategic Advisor interview Annabel Reoch, UK Head Anti-Bribery and Anti-Corruption, KPMG about the importance of transparency and challenging a collusive culture.....More
ICT compares results from the World Economic Forum publishes annual corruption index and Transparency International's Corruption Perception Index (CPI) in this Prezi presentation.
There is a good chance that corruption is a subject of both personal and professional concern to you. If that is the case, it is a sentiment you share with individuals the world over.....More
In a recent ICA article, we addressed the issue of de-risking and in particular the effect this is having in the Caribbean. The article referred to the fact that the United States are mostly responsible for the de-risking drive, and I want to highlight some of the indicators of this and also to look at why the U.S. are taking this approach.
We examine the case of automotive giant Volkswagen, the most recent household name to be hit by US authorities for breaching laws and regulations.
Modern slavery is a global issue that takes many guises and has the capacity to impact on businesses across many industry sectors.....More
We break down combined fines of nearly £18 million issued by the Financial Conduct Authority to five top offenders in 2016.
The Financial Action Task Force (FATF) released this month their first Mutual Evaluation of the United States since 2006.
Odebrecht and Braskem, two Brazilian companies, have been fined at least US$3.5 billion after pleading guilty to bribing government officials.....More
The President-elect of the United States is a man on more familiar ground on Wall Street than in Washington DC, and yet Donald Trump will surely be focusing his attention on the banks when he moves into the White House in January.
The Netherlands has a long history of navigating the world and trading with other countries. Trade creates wealth and is a vehicle to spread new knowledge and best practices. But trade also raises tremendous risks, especially in regions outside Western Europe and the United States.....More
Brexit has been a huge story all year, and will continue to be so throughout 2017 as Article 50 is triggered. Living and working here in the UK, I’m constantly bombarded with opinions telling me what the potential impact of leaving the EU could have on me and my family’s future. But what about the UK overseas territories? Gibraltar, for example, which, from memory, was the first region to declare their results from the EU referendum on June 23rd - voted an overwhelming 96% for the ‘Remain’ side. What are the implications of the overall result for this unique part of the UK?
Numerous reasons have been cited for Cyprus’s economic collapse, but one of the most enduring has been the charge of weak corporate governance in Cypriot banks. The demise of the now defunct Laiki Bank, previously the second biggest bank on the island, is indicative of the weak Governance, Risk and Compliance (GRC) framework that existed across Cypriot financial and governmental institutions.....More
Governance, Risk Management and Compliance (GRC) have been shown to be interconnected concepts. Applied effectively in a business, they can reduce costs, cut inefficiency and improve communication throughout an organisation; GRC can help ensure a businesses’ goals and objectives are better defined, the company structure improved and regulations properly adhered to. Indeed, strong GRC lays the foundations for potential company growth.
Sweden was the first country in the world to introduce freedom of the press as a constitutional right in 1766. This long tradition included the principle of freedom of information, giving both the general public and the mass media access to public records.....More
A round-up of our insight about money laundering, terrorist financing and beneficial ownership in Switzerland.
German companies have developed a complex supply chain integrated by thousands of third parties, subsidiaries and agents worldwide. As the strategic importance – and Compliance risks - of third parties increases, companies have to mitigate business risks while building trust in their partners.....More
German companies have developed a complex supply chain integrated by thousands of third parties, subsidiaries and agents worldwide . As the strategic importance – and Compliance risks - of third parties increases, companies have to mitigate business risks while building trust in their partners.
Corruption can be defined as ‘Dishonest or fraudulent conduct by those in power’ and usually falls into three main categories: grand corruption, petty corruption and political corruption, which the anti-corruption campaign organisation Transparency International defines more specifically.....More
Still wondering whether to come to the ICA Open Day (or one of the local sessions)? Then have a look at our infographic for a few compelling reasons to register your place this year...
A high percentage of Switzerland's surface is covered by the Alps. The melting of glaciers, located at the top of the mountains, generates flows of clean – and essential - water for a wide range of ecosystems downstream. This natural geological phenomenon helps us to illustrate the importance of the commitment from the Board of Directors and Senior Management to implement compliance across all hierarchical levels in Swiss companies.....More
Here in the UK, after weeks of blanket media coverage around Brexit, a change of Prime Minister and the legal complexities involved in the Labour leadership election, we could be forgiven for wanting a change of subject matter. So the Financial Conduct Authority’s (FCA) Annual Report for 2015/16 could provide a welcome respite for financial services professionals, though it’s not exactly what you might call light reading.
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