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Procurement Integrity and Supplier Selection
Procurement decisions move real money to real suppliers, which makes them a natural target for favouritism, kickbacks and manipulated bidding — and a natural place for firms to build strong,...
Outside Activities, Personal Interests and Directorships
A second job, a board seat, or a personal investment can be entirely legitimate — but for regulated and senior staff, these outside interests can also create real or perceived conflicts with...
Conflicts of Interest in Financial Services
A conflict of interest isn't automatically wrongdoing — it's a situation where personal, customer or institutional interests could improperly influence a decision. Left undisclosed and unmanaged,...
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Fraud Risk and Internal Controls
Occupational fraud — employees exploiting their position to benefit personally at the firm's expense — ranges from petty expense abuse to serious, sustained schemes involving asset...
Charitable Donations, Sponsorships and Community Investment
Charitable giving and sponsorship are genuinely valuable ways for firms to support their communities — but they can also be used to channel value to a decision-maker's favoured cause in exchange...
Third-Party Bribery Risk
Firms are typically liable for bribery committed on their behalf by third parties — agents, consultants, distributors — not just by their own employees. This makes third-party risk one of the most...
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Gifts, Hospitality and Entertainment
Gifts and hospitality sit in a genuine grey zone — a coffee, a modest lunch or a branded diary is normal business courtesy almost everywhere, while a weekend at a luxury resort timed just before a...
Anti-Bribery and Corruption Foundations
Bribery doesn't always look like a briefcase of cash changing hands in a car park. In financial services, it more often looks like an inflated invoice, a lavish hospitality package timed...
AML Governance, Testing and Model Effectiveness
An AML programme can look complete on paper — policies, procedures, systems, reporting lines — and still fail in practice if governance is weak, underlying data is poor, or nobody independently...
Human Trafficking and Modern Slavery Financial Indicators
Human trafficking and modern slavery leave financial footprints — recruitment fees, controlled wages, unusual account access patterns — that front-line and AML staff are sometimes uniquely...
Financial Crime Risk in Cryptoassets
Cryptoassets combine genuine financial innovation with financial crime risks that don't map neatly onto traditional banking controls — pseudonymous wallets, cross-border transfers in seconds, and...
Trade-Based Money Laundering
Trade-based money laundering (TBML) exploits the sheer complexity and volume of international trade — mismatched invoices, inflated or deflated pricing, and phantom shipments can move value across...
Correspondent Banking Financial Crime Risk
Correspondent banking lets a bank in one country offer services in another through a relationship with a local respondent bank, but this convenience comes with a distinctive risk: the...