Sounds a pretty daunting title but this was the focus of the 31st International Symposium on Economic Crime held in Cambridge. An amazing venue, at Jesus College, and a very impressive array of international speakers along with delegates from over 100 jurisdictions. I would urge you that if you have the opportunity then go to next year’s session.
I had a fantastic time there on Monday and Tuesday and wanted to just share some thoughts that I brought away with me.
Globally, and very clear from all speakers, was the message that ‘Ethics of truth must rule’. We were reminded by Global Witness that money launderers (and I would add terrorist financiers too) rely on two things. Firstly structures made available to them to hide their identity and then banks and professionals willing to do business with them.
Some of the key messages I picked up reflect the challenges still being seen?
Speakers from the smaller and more remote jurisdictions reminded us of the problems they face from the lack of resource (suitable staff salaries), coupled with a lack of experienced staff in dealing with the volume and frequency of updates from numerous sources on the regulatory requirements.
The question was posed - Are there are too many organisations involved in regulation and investigation of financial crime? In my opinion, this is probably a valid concern.
‘We need to be far better in sharing information at individual, business and country level’ and also ‘Companies need to have the confidence and ability to report financial crime and fraud’ (Stephen Head, Commander, City of London Police)
Threats are changing. New Zealand is number 1 on the Transparency International’s Corruption Perception Index. ‘A number of high profile cases, including PEPs, are arising given NZ’s main trading partner is now China’ (Simon McArley, Acting Chief Executive of the Serious Fraud Office of New Zealand).
Virtual currencies are, and will remain, a hot and challenging topic to be faced. Do these virtual currencies have the potential to destabilise the economy of a country? Given the figures quoted in the Liberty Reserve saga recently then the obvious answer must be yes this is a distinct possibility.
I have mislaid the source, but another great observation made was why do we not extend the business model in the UK Bribery Act on accountability and criminal liability to all financial crime? Good idea I suggest.
What struck me most though from the two days though was a reinforcement by all speakers of a message that came from the Financial Conduct Authority in the UK previously - that we must make it a hostile environment from the criminals.
This was no more clearly demonstrated, and really impacted me, than by what Catherine Ahn (Office of the General Council, Dept of Treasury, USA) said: ‘Governments have a fundamental duty to protect people by stopping the funding of terrorism’. Personally I would add that we all, not just the Governments, should have this as our fundamental duty.
Global Witness are right – not only must we look at the structures, products and services available to the terrorists but the banks, professionals and indeed all of us need to play our part in cutting off the supply of funds to these ‘people’.
Perhaps, therefore, we need some fundamental changes in our thought processes to allow us to bring a meaningful response or, to quote from George S Patton, ‘If everyone is thinking alike, then somebody isn’t thinking’.