Episode Transcript
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Speaker 1 (00:12):
Welcome everyone to
the RegTech Pulse podcast, where
industry experts discuss thelatest trends in financial crime
compliance.
I'm your host, julia Thorne,and today I'm pleased to be
joined by Eve Whittaker andVincent Gordell, who are going
to be joining me as we look backon the year that was 2024, and
also what 2025 might hold in theworld of regulation and
financial crime compliance.
(00:32):
So thank you so much for bothfor joining.
For those of our listeners whodon't know each of you, could
you just give us a littleintroduction of yourselves, your
role?
Maybe, eve, starting with you?
Speaker 2 (00:46):
Sure.
So my name is Eve Whittaker andI'm a market planning director
in the financial crimecompliance division and I work
with our teams in the UK and Iand the Germany, Austria,
Switzerland regions.
Speaker 3 (00:53):
Perfect and Vincent.
Yes, sure, hi everyone.
Thanks for having me on thepodcast.
So my name is Vincent Godel.
I work as an SME really aregulatory expert in the field
of FCC, so that includesinternational sanctions and AML.
Working within the marketplanning team together with Eve
and other folks in the region.
Speaker 1 (01:11):
Thanks, guys.
So every year, lexisnexis RiskSolutions release our
predictions for the top trendsto look out for in financial
crime compliance and we're goingto be covering off those five
trends during the course of thisepisode, but maybe starting by
looking back on 2024, vincent,I'll start with you.
What were some of your keytakeaways?
Big news stories that you thinkkind of summed up the year that
(01:34):
was 2024?
.
Speaker 3 (01:36):
Yeah.
So if we look at sanctionsfirst, we also have a regular
infographic, like we keep.
Obviously we keep track ofsanctions updates and big trends
in the world of sanctions, andI'm just finalizing the number
at the moment.
But 2024, in short, was anothervery busy year.
If you look at what we call themajor sanctions regulator so
that includes the United Nations, the US with the OFAC, eu and
(01:58):
UK it's really a very high,intense sanctions activity that
we observed since 2022.
It's really a very high,intense sanctions activity that
we observed since 2022.
And actually for last year, for2024, we have recorded an
increase of those four sanctionslists by more than 4,300
entities, which is actually 14%more entities than what has been
added in 2023.
(02:19):
So basically, the growth ofsanctions lists is not losing
momentum.
It continues to accelerate.
But there is an interestingtakeaway within that overall
number of 4,300 entities beingadded to those lists is that
this growth is really not evenlyspread across the four lists.
There is really a decoupling inthe increase of those lists,
(02:41):
primarily between the UN listand the other more national,
unilateral sanctions.
The UN list is actually verystable over time.
We have seen very minimalnumber of updates throughout the
year.
It's been the case for a coupleof years, but 2024 was no
exception and overall, a veryminor number of addition to the
UN list.
What we see instead is reallyintense national use of
(03:05):
sanctions, and primarily by theUS.
If we look at 2024 numbers,actually 72% of the new
additions were driven by OFACactions, by the US actions, and,
in terms of pace of updates,almost 50% of the actions were
driven by OFAC.
So there is really reallystrong leadership from the US in
(03:26):
terms of sanctions and theother ones are more or less
aligned with what the US isdoing.
Speaker 1 (03:32):
And Eve.
When we were talking aboutplanning this podcast, we were
talking about a lot of electionactivity.
Obviously, this week we sawDonald Trump go into the White
House after last year's election, but there was a lot more
election activity around theworld.
Could you expand a little biton that after?
Speaker 2 (03:45):
last year's election,
but there was a lot more
election activity around theworld.
Could you expand a little biton that?
Yeah, certainly 2024, as wellas being a very sanctions heavy
year, was a very busy year interms of general elections.
I think something like upwardsof 40 countries had some form of
general election, so there's ahuge amount of activity taking
place in that area.
Obviously, the US was one ofthe more high profile of those
elections, but a lot of majoreconomies around the world so,
(04:06):
including the UK, india, southAfrica there's been a huge
amount of activity and whatwe've seen in particular as well
, in a lot of these generalelections, the incumbent powers
were overturned, so we've got alot of new members of parliament
coming into their seats.
We've got a lot of new leadersin position, and this obviously
has implications for potentialforeign policy and that might
(04:28):
well shape what we see through2025.
But, in a more practical sense,for regulated institutions who
are performing due diligence andscreening, it means there are a
lot of new politically exposedpersons who are going to be
added to lists, and so it's beena lot of effort in terms of
making sure that the lists thatare being used for screening up
to date so that they're keepingup with all of that new election
(04:49):
activity and making sure thatall counterparties and so on are
effectively screened againstthem as well to fully understand
the risk.
So places a practical burden oninstitutions, for sure, but I
think also sets the precedentfor a very interesting 2025
ahead where we can expect to seenew governing policies and see
how that kind of continues toshape out, and so Yves, you
(05:10):
mentioned there around PEPsbeing one particular impact on
those lists.
Speaker 1 (05:13):
Looking to 2025,
Vincent, in terms of the impact
on sanctions lists, watch lists,what do you see coming to the
fore in terms of list updates orsort of changing regulations, I
suppose?
Speaker 3 (05:24):
Just to echo on what
you were saying, I think
something that is reallyinteresting like a great part of
those elections were snappedelections, like it was not
predicted.
Usually, when you talk aboutlike volatile list activities,
we have in mind or I have inmind sanctions, like unpredicted
sanctions developments, butthat can happen with PEPS as
well.
So that's really something tohave in mind, because when there
(05:45):
are changes that affect thelistings, that has really
impacts for institutions, as itwas pointed out.
So really, like the operationalburden to keep pace with the
changes has been heavy both onthe sanctions front and AML
front.
Now, the other side of the coin, yeah, with new PEPs, with new
political direction, we areseeing now the beginnings in the
(06:08):
US, but in the EU we had somepolitical changes as well.
There is a likelihood thatforeign policies will change as
well.
So we don't know exactly whatTrump's policy will be like.
We have seen a couple of like ahandful of for now fairly minor
changes, but we can expect somevery significant foreign policy
(06:29):
changes which will, in turn,impact the entities being listed
.
For those of us in thesanctions compliance community
that have been around in theprevious term of the Trump
administration, there were somepretty significant changes to
the US list when Trump tookoffice.
There was the withdrawal fromthe Iranian nuclear deal and
that resulted in a massiverelisting of Iranian entities.
(06:51):
That was really another painfulepisode for sanctions
compliance professionals.
So this type of radical changesin foreign policy orientations
should not be excluded for sure.
Speaker 1 (07:02):
And Vincent, one of
the trends that we highlighted
in that infographic was aroundexpanding regulatory reach, and
I wonder if you could expandexcuse the pun on some of the
ways that regulation might bechanging or how the arms of
those regulators may be gettinglonger.
Speaker 3 (07:15):
So what immediately
comes to mind when we talk about
expanding reach of regulationsis, first, the use of secondary
sanctions or similar mechanisms,like really for regulators to
apply an extraterritorialdimension to their sanctions.
So there was an interesting setof developments last year with
the US really applying secondarysanctions pressure in scope of
the Russian measures.
(07:35):
It's interesting because wehave seen earlier this month
like early January 2025, thattool being used against a
foreign financial institution bythe US.
So it was actually a bank fromthe Kyrgyz Republic that was
listed by OFAC under thosesecondary sanctions mechanisms.
So now it's not just a threat,you have an actual action on
those authorities.
(07:56):
There are some similar attemptson the EU side as well, but not
as clearly extraterritorialmeasures as the US, obviously.
But really that trend reallyexemplifies and illustrates the
willingness for regulators tomake sure their sanctions are
effective and they are reallyprepared and showing teeth to
tackle sanctions evasionwherever it occurs.
(08:17):
So that really illustrates theexpanding reach of regulators.
It's also pretty evident whenyou look at enforcement
decisions.
You see companies from everysector being enforced against.
You see, from last year, verydiverse sectors settling with
OFAC over violations ofdifferent programs and really
that trend, which is alreadyvery true in sanctions that no
(08:40):
industry is immune fromregulatory reach and all
industries should care.
We start to see a similardynamic in the AML world as well
.
So it's not for every industrybut we see a broadening and
expanding reach of AMLregulation as well.
We have a current focus on whatis called under FADF standard
as the designated non-financialbusinesses and professions, so
(09:02):
those professions are called thegatekeepers.
It includes really legalprofessions, company service
providers and the likes.
Those professions are becomingmore and more under scrutiny
from an AML standpoint and wesee some initiatives in
different places, like Australiahas recently released a
regulation to expand AMLrequirements to those
professions.
Because currently, if you lookat the FIDEF assessments, it's
(09:25):
one of the key weak spots, likeinternationally speaking, like
the ability of countries toreally regulate and supervise
those professions.
That is lagging overall andit's a key priority for the FATF
going forward.
So that's another facet of theexpanding reach of financial
crime regulation as a whole,Really kind of connecting the
(09:46):
dots on AML exposed professions.
That makes sense.
Speaker 2 (09:50):
Yeah, I have to agree
there's certainly been a huge
expansion in the scope ofregulatory pressure and that
obviously increases both thenumber of organisations that are
now subject to very stringentmeasures but also the efforts
that various institutions needto go to are expanding, and I
think one really high profileexample that we've seen kind of
(10:10):
throughout 2024 coming intoforce at the start of 2025, is
the introduction of the SIPAregulations.
So this is quite a Europeanspecific impact, obviously, but
I think the efforts thatorganisations have had to go to
to be ready to support instantpayments within that secure
European payment area has beenquite substantial and is another
(10:33):
example of that kind of uptickin effort that's expected.
But there are, I think, someother interesting implications
to that super regulation cominginto force.
So there are two pillars tothat that I think are kind of
interesting to dive into andthat might influence how we see
2025 shaping up ahead.
One is kind of this idea thatyou've created this secure zone
(10:54):
within which payments could betransferred, with all the banks
conducting regular, dailyscreening of their own customers
and therefore being able tosend payments within that area
without directly screening thepayment itself, and this sets a
really interesting precedentbecause it's the first time
really, that we've seenfinancial institutions be able
to place some level of relianceon the due diligence that's
(11:18):
being performed by anotherinstitution, as opposed to being
solely responsible forconducting both halves of that
due diligence piece.
And this, I think, sets a reallyinteresting precedent for
potentially being able tocollaboratively address
financial crime in the future,which is a topic that it feels
like we've been hearing a lotabout in the space now how
important it is for us to beable to co-rely on the
(11:40):
information of otherinstitutions.
No one institution has the fullpicture of risk and therefore
being able to potentially shareinformation in the future or at
least in the meantime, be ableto collaboratively rely on
counter due diligence, is reallyimportant and, I think,
potentially has reallyinteresting implications for how
we can start to tacklefinancial crime prevention in
(12:00):
the future.
Which is really interesting.
That is, of course, thatalthough this secure zone exists
for European institutionsspecifically, a lot of the
organizations impacted by thatregulation are still needing to
adhere to other internationalstandards, which means that in
reality, they're kind ofimplementing this new daily
screening approach of all oftheir customers but at the same
(12:22):
time, still conducting paymentscreening against other
international lists.
So once again, that complianceeffort is actually going to be
really significant.
So an interesting precedentbeing set, although perhaps not
having quite the practicalimplications of reducing
workload that were anticipated.
Speaker 1 (12:38):
So another trend that
we talk about in terms of links
to the regulation trends arearound this increasingly
concerning area of bribery andcorruption, thought to cost the
global economy $3.6 trillionglobally.
Eve, maybe one for you.
Why is this, on an ongoingbasis, such a tough area to
tackle and maybe what should theaudience listening in do to
(13:00):
consider when it comes tothinking about how they can help
in the fight against briberyand corruption?
Speaker 2 (13:04):
Bribery and
corruption certainly is a
significant issue and one thatis notoriously difficult to
tackle, I think, because it canbe a little bit ambiguous to
define and catch hold of thebehaviours and so on and risks
that are associated with it.
So there are many regulationsin place that are aiming to
directly tackle bribery andcorruption.
We have things like the OECD'sAnti-Bribery Convention, which
(13:28):
is in place, as well as specificregulations in a number of
countries, and a lot of regionshave been expanding the remit of
their anti-bribery andcorruption laws to try and make
them more effective.
So things like making it acorporate offence, like a
criminal offence, for corporatesto fail to detect effective
bribery controls and so on, andso we are seeing, I think, an
(13:50):
increased regulatory effort totry and address that, but it
does still remain a challenge.
One thing that has been observedis that almost all of the
penalties that the FCPA havelevied involve some kind of
third party, which puts a hugeemphasis on things like supply
chain due diligence and beingable to very thoroughly assess
all of the counterparties thatyou're working with across a
(14:11):
supply chain, and there's awider trend, I would say, in an
increased focus on things likesupply chain due diligence and
third party due diligence that'spicking up across the space.
In general, the EU have broughtin, for example, acts around due
diligence that obligatecorporations to dive into more
detail, and that expands beyondjust looking for bribery and
(14:33):
corruption.
It takes into account thingslike environmental risks, social
risks, human rights risks andso on, but I think is also a
really effective way to try androot out the kind of bribery and
corruption that can also oftenbe associated with those kinds
of activities.
So very, very thorough duediligence a full supply chain
and third parties is certainlyone of the ways that we can
(14:54):
start to identify and counteractthis.
I think, in addition to that,beyond just upfront due
diligence of the supply chain, acontinuous monitoring of
behaviour, looking at perhapstransactional analysis, but also
the dynamic risk profile ofcounterparties, is also one of
the most effective ways toattempt to capture that kind of
(15:14):
activity.
Speaker 3 (15:15):
Yeah, there's really
a strong development of those
regulations across the board andreally like building up these
supply chain decisions and Ithink it's really like the
missing pieces compared to whatwe already had in mind.
More from a financialstandpoint, the scrutiny on
politically exposed persons.
So once corruption wascommitted, that politically
(15:36):
exposed person might need tolaunder the proceeds right, and
that's where the financialsector plays a huge role in
really detecting when it dealswith politically exposed persons
and really apply an adequatelevel of due diligence on those
persons, because corruptionrisks they are real for these
prominent public figures.
So I think there is really acomplementary role from
(15:57):
international corporates toreally be vigilant with their
supply chain and the financialsector to make sure financial
transactions involving PEP makesense compared to their expected
financial resources, so tospeak.
And we really see therequirements and the AML
requirements on PEPS beingstrengthened in the latest AML
(16:18):
regulation in the EU primarily,and I think it's really a
complementary way to addresscorruption.
That is important to maintain.
And the last thing, and I thinkcould be another interesting
tool that is being used byspecific countries, so typically
the US and UK.
They also go after corruptionthrough international sanctions.
(16:38):
This is something that the EUhas been trying to implement but
has not yet come up with anactual sanctions program.
But the US is a very regularuser of sanctions against
corrupt officials, and the UK aswell, so it's kind of the tool
of last resort, so to speak.
But there is a possibility tofreeze the assets of corrupt
(17:00):
officials, and that's somethingthat we observe steadily, and
particularly last year we'veseen quite a number of
designations by the US and UKagainst corrupt officials from
different countries.
We've seen former officialsfrom Angola or even from
European countries actually fromLatvia, from Ukraine being
subject to asset freezes.
So it's an important issue.
(17:21):
As you were saying, it's reallya systemic issue and we need to
really use all tools availableto limit the possibility for
corruption to happen.
Speaker 1 (17:31):
So, speaking of tools
, now that we talk about ways
that we can help sort of fightsome of these challenges that
we're seeing, it's 2025.
We can't talk about trendswithout talking about AI.
One of the stats that we talkabout in the trends piece is
that 50% of financialinstitutions are using or are
planning to use AI and 70%believe that AI will lead to
(17:52):
more revenue.
So, eve, obviously you've got abit of a background in AI.
I wonder if you could talkabout how it's really impacting
the compliance space and whatyou see happening there.
Speaker 2 (18:02):
There's no doubt that
artificial intelligence can
have a massive impact on thecompliance space, the financial
sector in general, I think it'shaving a huge influence on, but
within the compliance spacespecifically.
There's huge potential there.
We know that it's a very datarich area and that one of the
key difficulties that a lot ofinstitutions have is working
(18:23):
with that data.
There's so much of it, it'soften in very disparate places,
it can be very hard to manage,and artificial intelligence
offers a real opportunity toactually be able to harness that
wealth of data and start todraw real insights from it that
can help to improve riskdetection but also massively
improve the efficiency ofcompliance processes.
(18:43):
So it gives institutions theability to really scale and
manage the expanding number ofrecords that they have to screen
, do things like, reduce falsepositives and therefore make
that workload more manageable,while also potentially being
more accurate in risk detectionbecause of being able to analyze
so much more data withoutneeding to rely on manual
(19:04):
efforts in particular.
So there's doubtless hugepotential that artificial
intelligence can bring, and Ithink it's become quite a
familiar term over the last fewyears.
The more familiar people getwith that technology, the more
reliable it will become and theeasier it will be for
organizations to effectivelyimplement it, and I think we can
also expect, as it becomes amore broadly adopted technology,
(19:26):
for the costs of implementingAI to start to come down as well
, making it more accessible fora broader range of institutions.
So certainly, I think that's atrend that we're going to see
continuing for years to come isthe adoption of AI, and it
offers a lot of opportunity, Ithink, not only in terms of
being able to manage riskeffectively, but also in
potentially allowing for moreaccurate risk decisions to be
(19:50):
made, which can therefore openthe door to better financial
inclusion.
So, if we're talking aboutleveraging models to make risk
decisions, they can often bemore nuanced by capturing more
data points, and this means that, rather than needing to make
blanket decisions aboutperceived high risk areas,
organisations can start to bemore nuanced about precisely
where risk may sit, and thismight therefore open the door to
(20:12):
financial access for broadergroups of people, which is a
really exciting prospect.
Of course, on the flip side ofthat, there is the potential for
bias to be perpetuated withinAI models, which is why a really
strong, responsible adoption ofAI is really important, which
I'm sure, vincent, you agreewith.
Speaker 3 (20:31):
Completely agree with
everything you said and
obviously the potential is huge.
But, yeah, the condition toreally reap the benefits is to
do it in a responsible mannerand yeah, really I think you
should not like for anytechnology, it's not a silver
bullet.
Right, there is potential there, but you have to implement it
by understanding what you do,right.
(20:51):
So it has been true for a whilewith compliance technology, we
know about those requirements tovalidate the models, to keep an
oversight on those screeningtechnologies, for example.
That requirement will obviouslyhold true for AI models as well
obviously hold true for AImodels as well.
So it's really key forfinancial institutions and other
businesses that want tointegrate AI into their
compliance programs to have theright set of human resources
(21:14):
internally to oversee how modelsare performing.
As you talked about bias, Ithink it's a perfect example
where you want to monitor howbias are avoided, because
ultimately, those tools canimpact very important decisions
to include or exclude someonefrom financial services.
So it's really important tokeep a good oversight on that.
(21:35):
I'm not sure if every FIalready have the right set of
human resources to administerthose complex models, but I
think the shift is happening nowand, yeah, we'll certainly see
some significant benefits, bothon the effective implementation
of a risk-based approach,something that we are trying to
power with technologies forquite some time, but also, as
(21:58):
you said, on the efficiency ofthose controls and like reducing
the overall cost and burden ofthose compliance controls.
Speaker 1 (22:05):
so, yeah, exciting
times ahead and we've talked a
lot about.
I think it's a nice way to kindof bring up the final point or
the final trend, which is aroundcustomer expectations and
customer experience, becausewe've talked a lot about, from a
regulated perspective, whatneeds to be done, from a
financial institution or acorporate, what needs to be done
, but there's also a very clearfocus on customer experience and
(22:25):
customer impacts.
And I also a very clear focuson customer experience and
customer impacts, and I wonderif both of you wanted to give a
little bit of information on,maybe, how some attitudes are
shifting or how there's more ofa priority in terms of allowing
for financial inclusion, likeyou just touched on a little bit
earlier yeah, I think it'sinteresting to observe basically
a trend to place the customerback at the center of those
(22:45):
processes, right.
Speaker 3 (22:46):
right, for different
reasons actually, because now
there is an increasingcompetitive pressure across
providers of financial services,so the incumbent banks are
faced with competition fromfintech etc.
And basically it means thatcustomers are less and less
eager to suffer the frictions,right, they don't wait for
agents to have access toservices, et cetera.
(23:08):
So that forces banks to do abetter job at applying the right
level of pressure.
It also makes sense really tothink about customer experience,
customer expectation, becauseit's basically about really
applying the principle ofrisk-based approach, right, so
if a customer doesn't presentparticular risk, you should not
apply undue friction.
(23:28):
So, yeah, it's really aboutmoving away from the legacy
box-sticking approach and reallythe formal approach to
compliance and really focusingefforts in situations of risk.
And that's really where thecustomer-centric approach can
help Up to the point that reallyan innovative, efficient
(23:49):
approach to compliance canbecome a competitive advantage.
Right, you can really easilyidentify areas where you can go,
whereas your competitors mightchoose to de-risk a particular
sector or types of activities.
With the good complianceresources, you can make informed
decisions and go in areas thatyou deem as within your
(24:10):
boundaries of risk tolerance.
So yeah, I think it's really aninteresting shift and a welcome
change.
Speaker 2 (24:16):
Yeah, I have to agree
.
I think that the idea of thecustomer-centric approach also
being a risk-based approachmakes perfect sense.
It puts the customer at theheart of the journey while also
fulfilling an effectivecompliance program right, which
is great to see.
I do think it's interestingwhen we think about the
possibility of compliance as acompetitive advantage.
(24:36):
We talked earlier about howimportant it is for
organizations to be able tocollaborate, potentially even to
share information and data inthe future, to really get that
full picture of risk.
So I suppose there's a balanceto be struck there between the
competitive edge that compliancecan offer not outweighing that
need for collaboration toultimately actually prevent risk
(24:58):
, which is the ultimate goalthat we all want to be working
towards.
So I do think there's probablya balance to be struck there
between the two.
But certainly it's great to seethe industry moving away from
what we call the box tickapproach and certainly more
towards a more true preventionof financial crime that puts the
customer at the centre as well,who we're all trying to protect
.
Speaker 1 (25:17):
I agreed.
So, wrapping things up, then,we've covered a lot of topics
today.
We've talked about AI, changingregulations, the importance of
collaboration, partnership,bribery and corruption, and then
increasing customerexpectations, and I think, if we
consider all of those trendstogether, each of you, what
would be your key takeaway, Iguess, in terms of challenges
(25:39):
not only challenges, butopportunities that you see maybe
presenting themselves in 2025?
Speaker 2 (25:44):
I think we can
certainly all agree that 2024
was quite a complex year interms of the introduction of
lots of sanctions programmes,lots of political activity, as
we've talked about today, and Ithink it's fair to assume that a
lot of that complexity willcontinue into 2025.
I think there'll be quite a lotof change and potentially new
(26:05):
programmes that complianceprofessionals need to address as
we move through the year.
But, that said, the increasingregulation, the shifts in
dynamics within the market alsocreate a really interesting
environment for innovation.
I think we're starting to seethe adoption of lots of new
technologies in the space thatcan make individuals more
efficient, make teams moreefficient, but also allow for
(26:27):
much more effective capture ofrisk, which is again the
ultimate objective here.
So I'm really excited aboutwhat 2025 will bring.
Speaker 3 (26:35):
Yeah, I agree with
that, and I will just complement
by saying one word that comesto mind is the word urgency.
I think it's urgent that weinnovate effectively.
The level of risks are alreadysuper high and, as you were
saying, if we can expect thecomplexity and the level of risk
to go to, only grow right.
So I think innovation is urgent, effective innovation and
(26:57):
really innovation that helpimproving the way we combat and
disrupt criminal networks.
This is really needed now.
So it's really urgent that thattechnology is adopted and that
we collectively, as an industry,do better to fight against
financial criminals, adversariesand all those murky actors that
(27:17):
operate out there.
Speaker 1 (27:19):
Amazing.
Yves Vincent, thank you so muchfor joining me today.
It's been great to talk to youabout these trends and what
options it might present for2025.
You're welcome.
It's been a pleasure Pleasureabout these trends and what
options it might present for2025.
Speaker 3 (27:28):
You're welcome, it's
been a pleasure, pleasure
speaking with you and thankseveryone for listening.
Speaker 1 (27:33):
If anybody listening
wants to download that
infographic, we will include alink in our show notes.
This was the RegTech Pulsepodcast brought to you by
LexisNexis Risk Solutions.
If you like this episode, youcan find previous ones on all
listening platforms and onrisklexisnexuscom.
Thank you so much for listeningand we hope to see you again
soon.