AFC Thoughts

The Role of Tookitaki's AFC Ecosystem in Creating a Culture of Compliance

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Tookitaki
30 Jun 2023
7 min
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In a world where financial transactions are becoming increasingly complex and international, the importance of a solid compliance culture within financial institutions can't be overstated. This blog will delve into the critical role of a robust compliance culture in combating financial crimes such as money laundering and how innovative platforms like Tookitaki's Anti-Financial Crime (AFC) Ecosystem can help foster such a culture.

Within a financial institution, a culture of compliance goes beyond ticking off regulatory checkboxes. It is a mindset of shared attitudes that values ethical conduct and commitment to adhere to rules, regulations, and best practices to prevent financial crime. It is about creating an environment where every decision is weighed with compliance in mind, and every action is taken, knowing full well the broader consequences of non-compliance.

In the upcoming sections, we will take a closer look at the current state of compliance culture, why a strong compliance culture is necessary, and how Tookitaki's AFC Ecosystem can make a significant impact.

Understanding Compliance Culture

At its core, a compliance culture is the establishment and embedding of norms and values within an organization that prioritize adherence to laws, regulations, standards, and ethical practices. These norms and values guide all decisions and actions within the organization, from the highest levels of management down to the individual employees.

A strong compliance culture is a non-negotiable prerequisite in the fight against financial crimes, such as money laundering or fraud. This is because financial transactions often involve multiple steps, intermediaries, and jurisdictions. Each of these steps presents an opportunity for oversight or negligence, which in turn can open the door to illegal activities. Thus, every individual within the chain of a financial transaction needs to be committed to the highest standards of compliance.

The Importance of Compliance Culture

A robust compliance culture forms the first line of defence against financial crime. With a strong culture of compliance, organizations can identify potential threats and prevent them from escalating into significant issues. A diligent approach to compliance helps foster trust with stakeholders, including clients, employees, and regulators, thereby protecting the organization's reputation and promoting long-term success.

Consequences of a Weak Compliance Culture

In contrast, a weak compliance culture can have severe ramifications. Non-compliance can result in substantial legal penalties, damage to reputation, loss of business, and decreased customer trust. In some cases, it could even lead to the revocation of the institution's license to operate.

For instance, the financial institutions implicated in the Panama Papers leak in 2016 suffered massive reputational damage and faced significant legal penalties. In many of these cases, a weak culture of compliance, characterized by a lack of oversight and a willingness to overlook suspicious activity, was a contributing factor.

In conclusion, an effective compliance culture is not just about avoiding penalties. It is about safeguarding the financial system's integrity, ensuring the trust of customers and partners, and fostering a working environment that prioritizes ethical conduct and due diligence.

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AML Compliance Culture: A Closer Look

Anti-Money Laundering (AML) compliance culture is a specific facet of a financial institution's overall compliance culture. It refers to the institution's collective attitude, behaviours, and understanding regarding preventing money laundering activities.

Despite the importance of AML compliance culture, the reality in many financial institutions is less than ideal. While regulatory authorities worldwide have increased their scrutiny and tightened the rules, several issues persist within organizations.

Prevalent Issues and Shortcomings

  • Compliance Fatigue: One of the most significant issues facing financial institutions is 'compliance fatigue'. This is characterized by a decrease in vigilance over time due to the constant strain of keeping up with evolving regulations, continuous training requirements, and routine tasks. Compliance fatigue can lead to oversights and mistakes, increasing the risk of money laundering activities going undetected.
  • Fragmented Approach: Many institutions still tackle AML compliance in a compartmentalized manner, often dividing the responsibility across various departments. This can lead to communication gaps, inconsistent practices, and difficulty in creating a unified compliance culture.
  • Lack of Adequate Training: While most financial institutions provide training to their employees, the quality, depth, and frequency of this training can vary significantly. Inadequate or infrequent training can result in a lack of understanding and adherence to AML policies.
  • Check-the-Box Mentality: There's a prevalent "check-the-box" mentality, where compliance is seen as a list of tasks to be completed rather than an integral part of the organization's operations. This viewpoint limits the compliance program's effectiveness as it does not promote understanding or engagement.
  • Resource Limitations: Compliance is often seen as a cost centre, leading to limited resources allocated to it. The lack of adequate resources hampers the institution's ability to maintain a robust AML compliance culture.

Addressing these issues is critical for financial institutions to effectively fight against money laundering and demonstrate their commitment to upholding the integrity of the global financial system.

The Benefits of a Strong AML Compliance Culture

A robust Anti-Money Laundering (AML) compliance culture is not just a regulatory requirement, but a crucial competitive advantage for financial institutions. Here's why:

  • Risk Mitigation: A robust compliance culture minimizes the risk of regulatory breaches, which can lead to hefty fines, reputational damage, and loss of business.
  • Reputational Protection: Compliance failures can cause substantial reputational harm. A strong compliance culture helps maintain a positive reputation in the market, leading to increased client trust and loyalty.
  • Operational Efficiency: A compliance-conscious workforce can help identify and rectify potential issues before they escalate, leading to increased operational efficiency.
  • Positive Employee Engagement: Employees who understand the importance of compliance feel more engaged and committed to their roles, leading to better performance and lower staff turnover.

Impactful Case Studies

  • Standard Chartered Bank: In 2019, Standard Chartered Bank was fined $1.1 billion by US and UK authorities for AML breaches and sanctions violations. An internal investigation revealed that a lack of a strong compliance culture and failure to maintain appropriate controls were key contributors to the breaches.
  • Danske Bank: Danske Bank faced a €200 billion money laundering scandal involving its Estonian branch in 2018. A subsequent investigation pointed to significant shortcomings in the bank's compliance culture and AML controls, highlighting the critical need for a robust compliance culture.

These cases underscore the immense costs associated with compliance failures and the importance of embedding a strong AML compliance culture within financial institutions.

Tookitaki's AFC Ecosystem: A Catalyst for Compliance Culture

Tookitaki's Anti-Financial Crime (AFC) Ecosystem, a community-driven platform, plays an instrumental role in fostering a compliance culture. It does this by promoting information sharing, facilitating access to global best practices, and providing actionable insights to stay ahead of financial crimes.

Understanding the AFC Ecosystem

At the heart of the AFC Ecosystem are two key components:

  • Typology Repository: A vast, federated database of money laundering patterns, enriched by experts worldwide. It keeps financial institutions updated with emerging trends and allows them to integrate these typologies into their AML systems swiftly and efficiently, enhancing their compliance efforts.
  • AFC Network: A global network of subject matter experts, who contribute to and validate the typologies in the repository. This community collaboration ensures the database's accuracy and relevance.

A visual representation of a typology is given below:

Typology - Fund transfer (1)

Key Features and Benefits

The AFC Ecosystem's features align perfectly with fostering a strong compliance culture. Here's how:

  • Access to Global Best Practices: AFC's community-based platform provides access to global anti-money laundering best practices, helping institutions learn from collective experiences and drive compliance.
  • Regular Updates: The Typology Repository keeps institutions abreast with the latest money laundering techniques, enabling proactive risk management.
  • User-Friendly Interface: The easy-to-use platform facilitates the seamless creation and sharing of typologies, encouraging a proactive approach towards compliance.
  • Data Privacy: The platform only operates on patterns and does not store any customer data, promoting compliance with privacy regulations.

By leveraging Tookitaki's AFC Ecosystem, financial institutions can stay compliant and cultivate a robust culture of compliance, an invaluable asset in the fight against financial crime.

The Role of the AFC Ecosystem in Cultivating Compliance

The AFC Ecosystem plays an invaluable role in fostering a compliance culture within financial institutions. It does so by introducing an environment that encourages proactive participation in combating financial crimes and providing tools that enable institutions to maintain pace with evolving trends.

Facilitating a Proactive Compliance Culture

The AFC Ecosystem fundamentally encourages active engagement. The platform's typology repository, which relies on the input and expertise of a network of financial crime professionals, promotes a proactive culture. In this collaborative environment, compliance is not just seen as a regulatory requirement but as a shared responsibility towards safeguarding the financial system.

Enabling Responsive Compliance Strategies

One of the significant challenges in cultivating a compliance culture is staying updated with the continuously evolving tactics of money launderers. The AFC Ecosystem addresses this problem head-on. The constant updating of the typology repository ensures that financial institutions are always aware of the latest tactics money launderers use. This access to knowledge allows them to be responsive, adjusting their compliance strategies as needed.

Envisioning a Future of Compliance Culture: The Role of AFC Ecosystem

To bring about meaningful change in the fight against financial crime, cultivating a robust compliance culture within financial institutions is an undeniable necessity. Compliance must extend beyond a mere regulatory requirement, transforming into a shared responsibility and an integral part of the institutional fabric.

Tookitaki's AFC Ecosystem plays a pivotal role in this transformation. Providing a collaborative and responsive platform fosters a proactive compliance culture that stays one step ahead of evolving financial crime trends. The AFC Ecosystem's robust typology repository and interactive AFC Network are at the core of this culture, empowering institutions to harmonize their strategies and actively prevent financial crime.

For financial institutions seeking to bolster their fight against financial crime, Tookitaki's AFC Ecosystem presents a valuable platform. Its emphasis on knowledge-sharing and collaborative engagement is the way forward for fostering a proactive, robust compliance culture. The fight against financial crime is a shared responsibility, and each financial institution has the power to make a significant impact. We invite all institutions, large or small, to explore the AFC Ecosystem and join us in creating a proactive culture of compliance. Together, we can strengthen the financial system's resilience against the global threat of money laundering. Let's create a safer financial future.

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Our Thought Leadership Guides

AFC Thoughts
18 Jul 2024
4 min
read

Typology Tales July 2024: Account Takeover Surveillance

We are pleased to share the latest edition of "Typology Tales" for July 2024. This edition highlights the new typologies that our Anti-Financial Crime (AFC) community has carefully analysed and selected. Our community's collective efforts are crucial in staying ahead of evolving financial crime threats, and we are grateful for your continued participation and contributions.

AFC Community’s Role

Each month, our dedicated AFC community comes together to analyze and evaluate newly created typologies, selecting those that can significantly enhance the ecosystem's ability to prevent and combat financial crime. The typologies chosen for publication are those that offer the most promise in terms of effectiveness and applicability across various scenarios.

Key Highlights from July 2024 

These typologies have been meticulously curated to ensure they provide robust and actionable insights, ultimately helping to safeguard the financial ecosystem.

Theme of the Month: Account Takeover Fraud (ATO)

Theme of the month

Account takeover fraud (ATO) is a type of cybercrime where unauthorised people access a user's account and use it for harmful purposes. This dangerous activity has increased significantly in recent times, posing a growing threat to both individuals and organisations. 

In this edition...

In this edition of Typology Tales, we delve into two typologies that compliance professionals can incorporate into their transaction fraud monitoring systems to proactively prevent account takeover in real time.

Typology 1: Surge in Multi-Party Transactions in Sizeable Values

Typology-multiple counterparty

A pattern of multiple parties making high-value transactions with one entity in a short period of  time suggests possible account takeover fraud. This requires a strategic review of transaction behaviours.

How It Works

  • The typology monitors transactions involving a single customer who receives or transfers funds with multiple parties within a short time span.
  • To identify potential account takeover risks, the typology groups transactions by the unique identifiers of senders and receivers within a specified time frame. By tracking these identifiers over a defined period, it can determine how many different parties have transacted with a particular entity.

  • Simultaneously, the typology aggregates the transaction amounts linked to unique senders and receivers.

  • It flags any entity that engages in transactions with a large number of different parties and exceeds a cumulative transaction threshold. This signals potential account takeover risks due to unauthorised access and high-value transactions.

Typology 2: Monitoring High-Value Transactions Across Multiple Payment Modes

15 - 2024 July Edition TT Typology tales-1-1-1-1

Financial institutions may implement advanced monitoring to detect high-value transactions between senders and receivers through various modes, aiming to uncover potential account takeover fraud.

How It Works

  • To effectively oversee the flow of funds, the typology tracks and aggregates transaction amounts based on the mode of transfer.
  • Transaction amounts, including those made through cash or alternative payments, are further aggregated by the unique identifiers of the sender and receiver over a specific period.
  • Entities showing high-value transactions across multiple payment modes over specified time frames are potentially flagged as suspicious. This increased activity may indicate that an account has been compromised and is being used to funnel funds illegally.

From the Media: Account Takeover Attacks Overtake Ransomware as Leading Security Concern

Research by cybersecurity firm Abnormal Security highlights that account takeover (ATO) attacks have become a top concern for security leaders. The 2024 State of Cloud Account Takeover Attacks report reveals that 83% of organisations experienced at least one ATO incident in the past year. 

Over 75% of security leaders rank ATOs among the top four global cyber threats, with nearly 50% facing more than five incidents annually and around 20% encountering over ten incidents. ATOs are now considered more significant than other threats such as spear phishing and ransomware.

Read More

Unite in the Fight Against Financial Crime

Financial crime is a pervasive issue that requires a collective, centralised approach to intelligence gathering. That's why we have created the Anti-Financial Crime (AFC) Ecosystem, a network of experts who work together to share knowledge and develop strategies for combating financial crime.

If you are an AFC expert, we invite you to join our efforts and help us grow the AFC Ecosystem. And if you know any other AFC experts, please refer them to us so we can continue to expand and strengthen our network. Together, we can make a real difference in the fight against financial crime.

Typology Tales July 2024: Account Takeover Surveillance
AFC Thoughts
01 Jul 2024
3 min
read

Account Takeover Fraud: Monitoring Entities Incorporated Long Back

In the evolving landscape of financial crime, financial institutions need to intensify their scrutiny of transactions from entities with a long history of incorporation but sporadic or recent activity. This increased vigilance aims to detect and thwart potential account takeover fraud within savings accounts, ensuring the safety and integrity of financial systems.

Given below is a typology from Tookitaki's AFC Ecosystem. It details how to ensure your monitoring system triggers alerts transactions from entities with a long history of incorporation

Understanding the Typology

Setting Up Entity Historical Profiles

Financial institutions employ a function known as the "Incorporation Date of the Entity" to track and record the incorporation dates and transaction activities of entities. This function helps identify entities that have been established long ago but have shown recent or sudden transaction activities, which could be indicative of fraud.

Function Configuration and Data Aggregation

  • Aggregate Fields: The system aggregates data on 'sender incorporation date' and 'receiver incorporation date.'
  • Aggregate Function: Using the collect_set function, the system compiles a unique set of incorporation dates for each sender and receiver, providing a comprehensive historical perspective of each entity's transaction timeline.
  • Group By: Transactions are grouped by unique identifiers like 'sender_hashcode' and 'receiver_hashcode,' linking each entity’s transaction history to specific account profiles.

Monitoring and Anomaly Detection

The system continuously monitors the transaction activities of these entities, comparing current transactions against historical data. Entities that have shown no or minimal transaction activities for a significant period since their incorporation are closely watched. A sudden spike in transactions, especially those of significant volume or frequency, triggers an alert. This scrutiny is particularly heightened if the entity's previous activity has been minimal or non-existent for years.

Group 16190-1

Flagging and Review Process

Transactions involving long-dormant entities resuming activity are flagged as high-risk. These flagged transactions undergo a detailed review to ascertain the legitimacy of the activity and to rule out any potential account takeover or other fraudulent intentions.

Investigative Measures

For flagged transactions, financial institutions conduct thorough investigations involving:

  • Background Checks: Verifying the entity's background.
  • Transaction Legitimacy: Confirming the legitimacy of the transaction.
  • Entity Ownership: Ensuring the entity's ownership and operational status.

Preventative Actions and Customer Interaction

If fraudulent activity is confirmed, financial institutions take immediate steps to:

  • Block further transactions.
  • Secure the affected accounts.
  • Possibly reverse fraudulent transactions.
  • Contact entity representatives for further clarification and to ensure all parties are informed of the situation.

Compliance and Reporting Obligations

All suspicious activities are documented and reported in compliance with regulatory requirements. This ensures that the institution remains compliant with anti-fraud regulations and aids in broader efforts to combat financial crime.

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Enhancement of Monitoring Systems

Based on findings and trends observed from monitoring these entities, financial institutions continually refine their detection algorithms and update their monitoring systems to better identify and prevent potential fraud.

By closely monitoring the activities of entities incorporated long ago but recently active, banks can effectively spot unusual patterns that may indicate fraudulent activities, such as account takeovers. This proactive approach helps safeguard customer assets and maintain the integrity of the financial system.

Final Thoughts

Financial institutions must remain vigilant and proactive in monitoring and analyzing transaction activities, especially those involving historically dormant entities. This typology, sourced from Tookitaki's AFC Ecosystem, highlights the importance of advanced monitoring techniques in detecting potential fraud.

We encourage anti-financial crime professionals to join the AFC Ecosystem to access unique typologies and leverage community-driven insights for enhanced fraud detection and prevention. Together, we can strengthen our defenses against financial crime and protect the integrity of our financial systems.

Account Takeover Fraud: Monitoring Entities Incorporated Long Back
AFC Thoughts
22 May 2024
3 min
read

The Globalization of Fraud: The Rise of Transnational Scams

In an increasingly interconnected world, the borders that once confined criminal activities are rapidly dissolving, aided by the rise of digitalisation and the pervasive reach of online platforms. The stark reality we face today is a landscape where fraudsters exploit digital payment systems to target individuals across the globe, particularly in the Asia-Pacific region. Organised fraud syndicates are not just local threats; they operate on an international scale, executing sophisticated scams that often outpace current preventative measures.

Case Study: A Transnational Crackdown on Job Scams

On 20 March 2024, a significant breakthrough came when the Commercial Affairs Department (CAD) of the Singapore Police Force and the Bukit Aman Commercial Crime Investigation Department of the Royal Malaysia Police joined forces in Kuala Lumpur. This joint operation was the culmination of extensive cross-border investigative efforts aimed at dismantling a formidable job scam syndicate.

Between October 2023 and January 2024, this syndicate deceived over 3,000 individuals, accumulating illicit gains of approximately $45.7 million. These scams primarily targeted Singaporeans, promising lucrative job opportunities that required victims to make upfront payments or divulge sensitive information under the guise of securing employment. The rapid escalation of these scams prompted an intensive collaborative investigation, which eventually led to the arrest of five Malaysians involved in laundering the proceeds from these fraudulent activities.

This operation not only highlights the severity and reach of transnational scams but also underscores the urgent need for global cooperation and shared strategies to combat these crimes effectively.

Job Scam

The Imperative of a Collaborative Approach

As we witness a surge in transnational fraud, the isolation of financial institutions in their silos makes them particularly vulnerable. The complexity and rapid adaptation of fraud strategies require that defences be equally dynamic and interconnected.

Collective Intelligence and Shared Responsibility

To counteract the evolving menace of cross-border fraud effectively, a collaborative approach is indispensable. The AFC Ecosystem initiative represents a commitment to fostering industry-wide cooperation and information sharing. Through this collective intelligence, we aim to establish a robust defence mechanism that not only identifies but also anticipates fraudulent activities, ensuring safe and secure societies. This shared responsibility is vital in creating an impenetrable barrier against the sophisticated mechanisms of modern financial criminals.

Considering the Typology of the AFC Ecosystem

Drawing from the AFC Ecosystem's insights, let's delve into the typology of transnational job scams. This framework is instrumental in understanding how these frauds operate and what measures can be employed to thwart their attempts.

Detailed Analysis of the Typology

Transnational job scams represent a highly organized and rapidly proliferating threat that exploits the aspirations of job seekers worldwide. These scams are not just about deceit regarding employment opportunities but involve intricate financial manipulations that siphon funds across international borders.

Operational Mechanics

  • Initial Recruitment: The scam begins with contact through social media or other digital platforms, where victims are lured with high-return, low-effort job offers.
  • Deceptive Promises: The roles are advertised as lucrative yet simple enough to attract a wide demographic, from students to the unemployed.
  • Financial Prerequisites: Victims are persuaded to make upfront payments or provide personal information as a part of the onboarding process.
  • Expeditious Expansion: To maximize profits before any potential crackdown, these operations quickly scale and replicate across various regions.

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Granular Red Flags and Risk Indicators

To effectively monitor and prevent these scams, it is crucial to recognise the following detailed risk indicators:

  • Value: Transactions often involve small amounts that are usually perceived as low-risk by victims, making them less likely to raise immediate alarms.
  • Volume: A high frequency of transactions complicates tracking and analysis, as the sheer number of transactions can overwhelm standard monitoring systems.
  • Velocity: The rapid succession of payments, coupled with potential chargebacks or cancellations, creates a chaotic financial trail that is difficult to follow.
  • Channels: Scammers predominantly use digital payment platforms, online banking, and occasionally cryptocurrencies to maintain anonymity and complicate tracing.
  • Anonymity: There is often a mismatch between beneficiary details and the purported employer, signalling a red flag for transactions.
  • Recurrence: Victims are frequently solicited for multiple payments under various pretexts, each justified as necessary for job commencement or continuation.
  • High-risk Geos: Payments are directed to accounts in high-risk jurisdictions or to those that are otherwise unrelated or suspicious, lacking any logical connection to the job or employer.
  • Geographical Inconsistencies: The involved countries often have no direct connection to the alleged job or employer, exploiting the complexities of international law and jurisdictional boundaries.

Harnessing Collective Efforts for Enhanced Security

The fight against transnational fraud is not a battle that can be won in isolation. It requires the concerted efforts of financial institutions, regulatory bodies, law enforcement, and the public. By adopting the typology provided by the AFC Ecosystem and vigilantly monitoring the detailed risk indicators, we can forge a path towards a more secure and resilient financial environment. This collective approach is our best defense against the sophisticated and ever-evolving landscape of global fraud.

The Globalization of Fraud: The Rise of Transnational Scams