Our research programme for 2019 is outlined below and centres around a couple of core themes: the importance and value of a strong Financial Crime culture in organisations; the future of cash in our society and the emerging technologies that can be used to combat different types of financial crime, corruption and terrorist financing.
Modern Slavery & Human Trafficking
Modern slavery & Human Trafficking are very much current issues in our society. Human trafficking is one of the most profitable crimes in the world, with forced labour generating an estimated profit of US$150b / year for organised criminal gangs. Some reports suggest there are between 40-50m people around the world in forced labour situations – usually found in the lower reaches of company supply chains.
On 29th July 2019, Themis held a Financial Crime Breakfast Club meeting in partnership with Dow Jones to expose the nature and scale of modern slavery and human trafficking in more detail.
Our senior panel included:
Dame Sara Thornton - The Independent Anti-Slavery Commissioner
Andrew Wallis OBE - CEO, Unseen
Ingrid Verschuren – SVP Data Strategy, Dow Jones
Tom Stancliffe – Co-founder, Tribe Freedom Foundation
Serious & Organised Crime
Themis Briefing: NCA’s 2019 National Strategic Assessment of Serious and Organised Crime.
The NCA has released the 2019 National Strategic Assessment of Serious and Organised Crime (SOC). This assessment sets out the key threats and scale of SOC in the UK.
Please see our latest briefing note, providing a summary of findings and practical tips to help firms enhance their own risk assessments and control frameworks.
Download the full report from the NCA here.
Laws & Regulations
Who is subject to the UKS Money Laundering Laws & Regulations?
The reality is that Financial Crime and Terrorist Financing affects us all.
A series of laws have been passed in the UK to try and combat this, including criminalising the proceeds of crime under the Money Laundering regulations, as well as measures to tackle Counter-Terrorism and make it an offence to support and finance terrorist organisations and acts. Download this article to find out more.
Themis Briefing: SRA Review finds too many law firms fall short on anti-money laundering.
The Solicitors Regulation Authority (SRA) has recently carried out a review of 59 law firms to assess their compliance with the 2017 Money Laundering Regulations. In a damning report, the SRA outlined their key findings and as a result of this review, 26 of the 59 firms have been put straight into disciplinary proceedings with the SRA.
The review included sampling the AML frameworks, policies and procedures of law firms regulated by the SRA as well as a sample of client files to examine each firm’s identification and assessment of AML risks, their AML processes, their approach to Trust and Company Service Provider (TCSP) work and how they mitigate these risks.
Themis has written a briefing note to help our Themis members from the legal profession (and other interested parties) understand the key findings of the SRA review.
SRA Warning Notice can be found here.
Emerging Technology in Financial Crime: An analysis and rating of the best solutions for firms looking to strengthen their Financial Crime systems and controls.
The dark web, encryption, virtual private networks, cryptocurrencies & peer-to-peer transactions have enabled criminals to conduct their business free from traditional surveillance methods. The same technology is changing how law enforcement agencies respond to emergencies, conduct surveillance, manage data and improve their internal communications. Financial institutions are also turning to RegTech to fill compliance gaps, save on the costs of compliance, get ahead of requirements before deadlines and detect enterprise risk before the regulators.
For all these reasons and more, the global RegTech market is expected to grow from $4.3b in 2018 to $12.3b by 2023, focusing on cloud computing, big data, artificial intelligence (AI), machine learning (ML) and natural language processing (NLP). But as investment floods in to the sector it can be hard to understand the range of technology that is available and the trends that firms must keep ahead of.
Themis is conducting an extensive, industry wide study assessing the emerging technology landscape and producing a full report on the most effective financial crime solutions in the market today. Different solutions will be analysed, categorised and rated all in a handy easy to use guide for organisations to better understand the most suitable options for their specific business needs.
We are encouraging as many technology vendors and users to take part in our initial survey.
Understanding the strategic value of a strong Financial Crime culture.
Themis are working on an industry wide, authoritative report on the meaning & strategic value a strong Financial Crime culture.
Before looking at specific Financial Crime risks and controls within any organisation, it is important to assess the overall AML culture within the firm. Why? Poor culture is widely accepted as a key root cause behind many of the major Financial Crime scandals that have been well publicised in the global media over recent times. National and international regulators have been increasing the size and frequency of their investigations and fines for banks but increasingly the media and public opinion are turning against many other types of institution as stories of modern slavery & human trafficking, bribery & corruption are revealed to be inherent across many aspects of our public life, from schools to health, high value dealers, sports agencies and governments themselves. Boards who can get their culture right are making a key investment into their business franchise. Our report aims to show the true strategic value of focusing on culture over remediation and will include an analysis of:
The Financial Crime landscape;
Why is this so important? What are the impacts of Financial Crime on our society and businesses. What are the impacts on organisations of getting it wrong?:
Where are we now? The current situation and how firms have responded, including an analysis of key challenges and best practises;
Setting out the way ahead – key recommendations from the report findings.
This analysis will include results from a wide ranging survey of both public and private sector organisations as well as a series of structured interviews with senior figures from government bodies, regulators, law enforcement, banks and other regulated firms.
Cash is King (no more): Exploring the risks of cash from a financial crime perspective.
It may surprise you to know that cash is no longer the predominant payment mode in the UK, although criminals and criminal organisations will still continue to rely on cash. Notes are easy to pass around and don’t come with an audit trail. For those with criminal intent and half a brain, it is fairly easy to clean dirty money.
As a result of the higher Financial Crime risks associated with cash, many banks in the UK are scaling down their retail banking and cash-based services. However, in certain cultures cash remains king even for legitimate, honest business.
In this short research paper, Themis will analyse the financial crime risks associated with cash, the UK regulatory view, and explore whether there is risk of exclusion amongst those that either rely heavily on cash (eg: Ultra High Net Worth Individuals from certain cultures) or can only use cash because they don’t have access to other banking services.