In this episode, we unpack the multifaceted world of dormant accounts—what they are, the risks they pose, and how they’re managed across different contexts. We explore best practices for identifying and securing inactive accounts, from fraud prevention to working with executors, while addressing potential risks like identity theft, unexpected fees, and credit score impacts. We highlight the UK’s Dormant Assets Scheme, a voluntary initiative aimed at reuniting people with their forgotten financial assets or redirecting them to social and environmental causes. The episode also examines the role of dormant accounts in fraud detection, with sudden reactivation or large transactions serving as potential red flags, and stresses the need for long-term monitoring strategies. Finally, we discuss the critical importance of identity verification in safeguarding dormant accounts, protecting savings, and ensuring access to compensation schemes.
In this episode, we cover a recent enforcement case from the UK’s Financial Conduct Authority (FCA) involving the conviction of Daniel Pugh, who ran the £1.3 million Imperial Investment Fund—a Ponzi scheme that defrauded 238 investors. Largely promoted through Facebook, the scheme lured victims with promises of unrealistic daily, weekly, and annual returns. We discuss the charges brought against Pugh, including conspiracy to defraud and breaches of the Financial Services and Markets Act 2000 for unauthorised regulated activity and unlawful promotions. The FCA has reaffirmed its commitment to tackling financial crime and will now pursue confiscation proceedings to recover the illicit profits from this case.
In this episode, we shine a spotlight on major financial crimes—money laundering, fraud, bribery, corruption, and market abuse—unpacking their definitions, common perpetrators, and methods, including the three-stage laundering process of placement, layering, and integration. We examine why certain financial products and corporate structures are especially vulnerable, and how strong measures like customer due diligence (CDD), enhanced checks for Politically Exposed Persons (PEPs), and robust internal controls can help prevent abuse. The episode also explores the rising importance of ESG factors, the role of conduct risk management in fostering a customer-first culture, and the need for prudential compliance to maintain market stability. Throughout, we highlight how effective GRC frameworks—supported by continuous staff training—form the backbone of prevention and resilience in the fight against financial crime.
In this episode, we focus on the real-world application of Governance, Risk, and Compliance (GRC) within organisations. We break down what effective GRC looks like in practice, exploring the standards that guide firms in building strong controls and demonstrating the value of well-implemented frameworks. The episode highlights the vital roles and responsibilities of compliance functions and professionals, including the key skills and attributes needed to succeed in this field. We also examine how GRC connects with organisational culture and ethical practices, making the case for a proactive, forward-looking approach to regulatory change rather than a reactive one.
This episode provides an overview of the Travel Rule's implementation across various global jurisdictions. The Travel Rule requires Virtual Asset Service Providers (VASPs) to share customer data during virtual asset transfers to combat money laundering and terrorist financing. Different countries have established varying thresholds, some having zero-threshold rules where all transactions are subject to the regulation, and others setting a minimum transfer amount. Compliance dates and specific requirements, such as those for self-hosted wallets, also differ widely. Some jurisdictions are actively enforcing the Travel Rule, whereas others are in a grandfathering period or have not yet set a date for implementation. VASPs must navigate these differing regulatory landscapes to ensure they comply with the relevant laws.
The European Commission published guidelines in 2025 outlining prohibited artificial intelligence (AI) practices as defined by Regulation (EU) 2024/1689 (AI Act). These guidelines clarify the Commission's interpretation of Article 5 of the AI Act, ensuring consistent application across member states from February 2025. The document details specific AI practices considered harmful and in violation of fundamental rights, such as manipulative AI, social scoring, biometric categorisation, and untargeted scraping of facial images. It further addresses exceptions, enforcement, and the interplay with other Union laws, like data protection and non-discrimination regulations. The guidelines are non-binding practical guidance for competent authorities and AI providers to ensure compliance, aiming to protect fundamental rights while promoting innovation. The commission will provide additional support and will review and update the guidelines as needed.
The Financial Conduct Authority (FCA) examined ongoing financial advice services to ensure consumers receive the services they pay for. The review analysed data from 22 firms regarding suitability reviews, finding they were mostly delivered. However, some clients declined reviews, and a small percentage of firms failed to offer them, raising concerns. The FCA expects firms to rectify any shortcomings and proactively contact affected consumers, potentially offering redress where services were not provided. The FCA also provided guidance on good and poor practices observed during the review. Further, they plan to review existing rules for ongoing advice considering market developments and the Consumer Duty. Consumers are advised to complain to firms directly if concerned, utilising resources like MoneyHelper and the Financial Ombudsman Service if needed.
Covering an article from Merkle Science reports on a $1.5 billion hack of the Bybit cryptocurrency exchange, highlighting vulnerabilities in multi-signature cold storage. The attackers manipulated the user interface of transaction verification tools, causing operators to unwittingly authorise a malicious transfer, and the stolen funds were then laundered through complex methods including DEXs, address layering and non-KYC exchanges. This incident is similar to breaches at WazirX and Radiant Capital, indicating a broader systemic issue. Bybit responded swiftly, freezing assets and processing withdrawals efficiently, while Safe Wallet implemented enhanced security measures, and the incident is used to discuss recommended countermeasures including MPC wallets and improved training, The article also links the Bybit hack to other exchange breaches and stresses the need for stronger security and blockchain forensics to protect digital assets.
The European Union has enacted significant sanctions against Russia in response to human rights abuses, its aggression against Ukraine, and hybrid threats. These measures specifically target individuals and entities responsible for severe human rights violations, the repression of civil society and democratic opposition, and those undermining the rule of law. Sanctions include travel bans, asset freezes, and prohibitions on providing funds to listed individuals and entities, including penal colonies, judicial figures involved in politically motivated cases, and high-level officials. Furthermore, the EU has imposed trade restrictions on equipment that could be used for internal repression or for monitoring telecommunications. These actions demonstrate the EU's condemnation of Russia's actions and its support for human rights and democracy.
This Episode covers the the European AI Office's repository of AI literacy practices, which is intended to help companies comply with EU regulations. It highlights limitations of the repository, such as the vague descriptions and KPIs, the broad size and sector categorisations, and its non-recommendatory nature.
This research from CEPII examines the economic impact of sanctions on Russia, particularly concerning strategic and dual-use goods. Sanctions do not entirely block access to these items, but they do increase import prices, especially from non-sanctioning countries. The price index of Russian imports saw a notable jump after sanctions were implemented. Strategic goods have experienced a particularly steep increase in transportation and insurance costs. Despite China becoming a major supplier, sanctions have generally made obtaining crucial goods more challenging, costly and of lower quality for Russia.
A law firm, WGS Solicitors, and one of its partners, Bridget Catherine Miller, have been penalised by the Solicitors Disciplinary Tribunal (SDT) for breaches of anti-money laundering regulations. The firm admitted to failures, including improper handling of client funds and inadequate customer due diligence between 2017 and 2021. WGS Solicitors received a fine of £25,258, while Miller was fined £3,500. The SDT found that Miller, as the solicitor responsible for certain client matters, should have ensured necessary customer due diligence was conducted. Mitigating circumstances were considered, with the firm citing a failure to fully grasp the extent of the 2017 Money Laundering Regulations. The Law Gazette reported on the ruling, detailing the specifics of the charges and the resulting penalties, alongside other legal news and resources.
FinCrime Central reports that the UK Gambling Commission is concerned about the gambling industry's AML compliance, highlighting failures in scrutinising customer data and verifying the source of funds. The rise of AI-generated fake documents and cryptocurrency use for illegal transactions are significant emerging threats. The Commission is piloting financial risk assessments and collaborating with UK banks to combat gambling-related financial harm. Other articles discuss a Belgian sanctions dilemma, dismantling a money laundering syndicate, and South Korea reversing its ban on institutional crypto trading. These issues collectively emphasise the need for robust AML measures and vigilance against financial crime in an evolving landscape.
The White House document details an executive order mandating increased Presidential oversight of independent regulatory agencies. This order seeks to ensure these agencies are accountable to the President and, through him, to the American people, by requiring regulatory actions to be reviewed by the Office of Information and Regulatory Affairs (OIRA). The Government Executive article reports on this same executive order, highlighting its aim to curtail the autonomy of agencies like the FCC, FTC, and SEC. It cites experts who predict potential legal challenges, as Congress has historically shielded these agencies from White House intervention. The directive also restricts executive branch employees from interpreting laws in ways that contradict Presidential or Attorney General opinions. Furthermore, the order calls for agency leaders to consult with the administration and for the OMB to manage agency performance and funding.
A recent executive order signed by President Trump has paused future investigations and enforcement actions related to the Foreign Corrupt Practices Act (FCPA). This order directs the US Attorney General to revise FCPA guidelines, potentially prioritising American economic interests and foreign policy objectives. While the FCPA itself remains law, this halt could create uncertainty, particularly regarding international bribery laws. It is important to note, though, that other bribery laws will remain in effect. Companies must still maintain compliance programs due to potential future enforcement and international anti-corruption laws. Businesses should also increase their due diligence in regions where cartels operate.
The episode highlights a shift in global anti-corruption efforts, spurred by the US's recent decision to retreat from this arena. It argues that the UK must now step up, filling the void left by the US, which was historically a leader in combating financial crime and kleptocracy. The piece criticises the UK's past involvement in facilitating corruption through tax havens and anonymous shell companies but notes recent improvements in transparency and law enforcement. It suggests that reversing these improvements would be a mistake, urging the UK to prioritise the rule of law over short-term economic gains, especially with Trump's recent policy.
Hong Kong's Securities and Futures Commission (SFC) has released a regulatory roadmap called "A-S-P-I-Re" to future-proof the region's virtual asset ecosystem. This framework, detailed in the document, addresses the complexities of the virtual asset market, valued at over US$3 trillion, and the need for balanced regulation. The roadmap's five pillars - Access, Safeguards, Products, Infrastructure, and Relationships - outline 12 initiatives designed to streamline market access, optimise compliance, expand product offerings, modernise infrastructure, and empower stakeholders. It responds to the evolving landscape with strategies for managing liquidity, regulatory arbitrage, and investor protection. The SFC seeks to strike a balance between promoting innovation and mitigating risks by harmonising global standards and integrating traditional finance principles with blockchain technologies. Ultimately, the roadmap aims to solidify Hong Kong's position as a trusted hub for virtual asset liquidity through pragmatic and adaptive measures.
Criminal elements are increasingly exploiting cryptocurrency platforms, utilising sophisticated technologies like AI to perpetrate fraud and launder illicit funds. Regulators worldwide are responding with increased scrutiny and enforcement actions against crypto exchanges, particularly concerning anti-money laundering compliance. AUSTRAC, the Australian financial crimes regulator, has put numerous local exchanges on notice for failing to report suspicious transactions, reflecting a broader effort to combat criminal exploitation of digital assets. The crypto industry argues for clearer regulatory frameworks to differentiate legitimate businesses from illicit actors, emphasising the need for balanced regulation that fosters innovation while protecting investors. The interplay of technological advancement and regulatory oversight is crucial for ensuring the future adoption of crypto and combating financial crime within the digital asset space. Some jurisdictions are now becoming more crypto friendly, with appointments of figures who favour digital asset innovation.
AUSTRAC, the Australian financial crimes regulator, is scrutinising cryptocurrency exchanges due to concerns about money laundering and the financing of illegal activities. The regulator has issued notices to 50 exchanges suspected of failing to report suspicious transactions and has already taken action against several firms. These actions include deregistering some exchanges and imposing conditions on others. The cryptocurrency industry is advocating for clearer regulations, arguing that compliance is expensive and that legitimate businesses are being unfairly tarnished. The industry asserts its technology is better equipped at identifying and stopping illicit activity than traditional financial institutions. Despite some international interest in crypto assets, AUSTRAC remains concerned about the potential for misuse due to the ease of moving large sums across borders.
The Council of the European Union updated its list of non-cooperative tax jurisdictions, retaining the same 11 nations previously identified. The update acknowledges cooperative efforts from some jurisdictions to improve tax governance. Costa Rica and Curaçao were removed from a monitoring document after addressing deficiencies in their tax information exchange. Brunei Darussalam has committed to amending its foreign-source income exemption regime. The EU's list, established in 2017, aims to promote global tax good governance by assessing jurisdictions against criteria including tax transparency and fair taxation. The Council plans to revise the list again in October 2025.
