We often use the analogy of payments being a little like plumbing – it tends to be hidden away out of sight, and as long as water comes out of the tap, then we generally don’t think about the pipes themselves.
A few weeks ago, I had the opportunity to attend another annual ACAMS AML & Financial Crime Conference in Las Vegas, Nevada. We all know conferences are a convenient way to spend time with customers and prospects, meet with partners, hear about the ever-evolving market challenges, and watch fellow AML professionals share case studies and lessons learned. But sometimes these conferences can be a whole lot of re-hashed stuff masked as “the new challenges you’ve yet to face, or best practices that you must adopt.”
Thanks to standardized fraud reporting in the UK, we know that Authorised Push Payment fraud (APP) makes up around a third of all UK banking and payments fraud. At £354.3 million, it’s larger than remote banking fraud by about 2.5 times and increased substantially from the first proper recoding in 2017.
Across Europe and Asia, the term “suitability” seems to be as popular as the tongue-in-cheek reference “Brexit.” With the Financial Conduct Authority (FCA) in the UK leading the charge, regulators are consistently reevaluating their expectations surrounding suitability rules, and because of this continual change, there has been uncertainty in the marketplace.
Beneficial Ownership continues to be a hot topic of discussion across the globe. After the wave of new and clarified regulatory requirements in 2018, the fact that heated debate on this topic continues should come as no surprise. Whether it is the Fifth EU Directive (AMLD5), FinCEN’s Beneficial Ownership Final Rule, or FINTRAC’s Beneficial Ownership Amendments, all these guidelines seek to provide more clarity behind the reality and nature of the persons behind legal entities or shell companies.