Large-scale transformation in financial services is one of the most demanding things an organisation can attempt. The regulatory environment is complex, legacy systems are deeply embedded, customer expectations are changing rapidly, and the pace of external change shows no sign of slowing. Most writing on transformation focuses on strategy,
The UK Bribery Act 2010 is now fifteen years old. It has been in force long enough for organisations to have built their anti-bribery programmes, trained their staff, and satisfied themselves that they are compliant. And yet, when you examine those programmes closely, a consistent pattern emerges. Many organisations
The Money Laundering Reporting Officer is one of the most demanding roles in financial services. It carries significant personal liability, operates at the intersection of law, regulation and business, and requires difficult judgment calls, often with incomplete information, under time pressure, and in the knowledge that getting it wrong has
Regulatory change is one of the most demanding things a financial institution can be asked to do. The obligation arrives from outside. The deadline is fixed. The consequences of getting it wrong are public and painful. And the organisation is expected to deliver it alongside everything else already in flight.
The failure-to-prevent model has become the default global framework for enforcing corporate accountability for economic crime. Many organisations have not kept pace. What began as a single provision in the UK Bribery Act 2010 is now expanding rapidly across jurisdictions, reshaping corporate liability and the standard regulators expect
Ask any senior leader what matters most, and culture will be near the top of the list. Ask whether their culture is where it needs to be, and most will say there is work to do. Ask what they are doing about it, and you will hear about a programme.
The risk-based approach to AML is not new. It has been the cornerstone of financial crime compliance for more than two decades, embedded in legislation and regulatory frameworks across over 200 jurisdictions. Most compliance professionals can describe it without thinking. And yet it remains one of the most consistently
