Institute for Financial Integrity

𝗘𝗻𝘃𝗶𝗿𝗼𝗻𝗺𝗲𝗻𝘁𝗮𝗹 𝗰𝗿𝗶𝗺𝗲𝘀 𝗮𝗿𝗲 𝘁𝗵𝗲 𝟯𝗿𝗱 𝗹𝗮𝗿𝗴𝗲𝘀𝘁 𝗶𝗹𝗹𝗶𝗰𝗶𝘁 𝗮𝗰𝘁𝗶𝘃𝗶𝘁𝘆 𝗴𝗹𝗼𝗯𝗮𝗹𝗹𝘆, ranking only behind the drug trade and counterfeit trade. The illicit wildlife trade is highly lucrative, with traffickers estimated to earn between $𝟳 𝘁𝗼 𝟮𝟯 𝗯𝗶𝗹𝗹𝗶𝗼𝗻 𝗽𝗲𝗿 𝘆𝗲𝗮𝗿. 🐘🐅 Around 4,000 wildlife species were trafficked illegally from 2015-2021. Despite concerted efforts from international, national, and regional authorities to curtail wildlife trafficking, it’s likely the 𝗶𝗹𝗹𝗶𝗰𝗶𝘁 𝘁𝗿𝗮𝗱𝗲 𝗶𝘀 𝗶𝗻𝗰𝗿𝗲𝗮𝘀𝗶𝗻𝗴 𝗶𝗻 𝗮𝗰𝘁𝗶𝘃𝗶𝘁𝘆.  💰 Transnational criminal organizations are increasingly involved in every stage of the illicit wildlife trade, from the sourcing of live specimens, to import and export, storage, and manipulation of demand. Corruption is rife as illicit actors bribe officials in nature reserves, shipping ports, and other parts of the supply chain to facilitate trafficking.  🕵 FinCEN reported 212 Suspicious Activity Reports concerning illicit wildlife trafficking were filed between 2018 and 2021, 66% of which came from depository institutions and 24% from money services businesses. 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻 𝗽𝗿𝗼𝘃𝗶𝗱𝗲𝗱 𝗯𝘆 𝗳𝗶𝗻𝗮𝗻𝗰𝗶𝗮𝗹 𝗶𝗻𝘀𝘁𝗶𝘁𝘂𝘁𝗶𝗼𝗻𝘀 𝗽𝗹𝗮𝘆𝘀 𝗮𝗻 𝗶𝗺𝗽𝗼𝗿𝘁𝗮𝗻𝘁 𝗿𝗼𝗹𝗲 𝗶𝗻 𝗱𝗲𝘁𝗲𝗰𝘁𝗶𝗻𝗴 𝘄𝗶𝗹𝗱𝗹𝗶𝗳𝗲 𝘁𝗿𝗮𝗳𝗳𝗶𝗰𝗸𝗶𝗻𝗴 𝗮𝗻𝗱 𝗵𝗲𝗹𝗽𝗶𝗻𝗴 𝘁𝗼 𝗶𝗱𝗲𝗻𝘁𝗶𝗳𝘆 𝗼𝗳𝗳𝗲𝗻𝗱𝗲𝗿𝘀. ℹ For instruction on how to file a Suspicious Activity Report relating to environmental crimes, refer to FinCEN Notice FIN-2021-NTC4: https://lnkd.in/dy-p8JQ5

Check out Ruth Ochonma's update on this week's SEC approval of spot Ethereum ETFs 👇 We look forward to discussing regulatory compliance developments for digitals assets on tomorrow's webinar. 🔗 https://lnkd.in/e6kz6bDB

🍁 FINTRAC released a special bulletin on financial activity associated with suspected sanctions evasion. 𝘞𝘩𝘢𝘵 𝘴𝘩𝘰𝘶𝘭𝘥 𝘊𝘢𝘯𝘢𝘥𝘪𝘢𝘯 𝘧𝘪𝘳𝘮𝘴 𝘢𝘯𝘥 𝘧𝘪𝘯𝘢𝘯𝘤𝘪𝘢𝘭 𝘪𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯𝘴 𝘶𝘯𝘥𝘦𝘳𝘴𝘵𝘢𝘯𝘥? Learn more in our latest article. https://lnkd.in/g9FfmuZZ 𝗞𝗲𝘆 𝗧𝗮𝗸𝗲𝗮𝘄𝗮𝘆𝘀 ⚠️ Sanctioned entities use well-established money-laundering techniques to evade sanctions. 🔎 Sanctions compliance teams should collaborate closely with AML/CFT teams to detect and deter financial crimes. 📈 Convergence between sanctions and AML is becoming more significant.

⏰ Reminder to join us this Thursday for an action-packed agenda discussing all things digital assets compliance. Register here 👉 https://lnkd.in/e6kz6bDB Panelists: ♦ Andrew Rosenberg, Senior Director, Ripple ♦ Elizabeth Severinovskaya, Managing Director, K2 Integrity ♦ Catherine M Woods, JD, Associate Managing Director, IFI Moderator: ♦ Ruth Ochonma, Associate, IFI We hope to see you there!

¡Buenas from Chile! After an exciting flight over the Andes, Institute for Financial Integrity's Natalie Pulsifer and Catherine M Woods, JD arrived in Santiago to deliver an in-person Russia sanctions training program to the Chilean public and private sector on behalf of the U.S. Department of State. Participants included delegates from the Central Bank of Chile, Financial Intelligence Unit, National Intelligence Agency, Customs, Center for Non-Proliferation Studies, compliance firms, banks, and other financial institutions.   Notable topics of discussion included: 🔹Jurisdictional reach of the U.S., EU and UK in implementing unilateral sanctions regimes 🔹Key controls in protecting against sanctions evasion and export control violations 🔹Beneficial ownership information and how it affects sanctions compliance as well as AML controls 🔹A discussion on sanctions compliance in relation to digital assets, and applicability of U.S. jurisdiction 🔹Chile’s progress towards implementing its own export control program Thank you to our instructors, Crowell & Moring’s Dj Wolff and K2 Integrity’s Ladan Archin, for facilitating the training and leading such important discussions, and to our partners from the U.S. Embassy, including Bethsaida Romero, for making this program a success!

The “three lines of defense” model is a widely recognized approach for effectively managing financial crime and regulatory risk. 𝗕𝘂𝘁 𝗵𝗼𝘄 𝗱𝗼𝗲𝘀 𝗶𝘁 𝘄𝗼𝗿𝗸 𝗶𝗻 𝗽𝗿𝗮𝗰𝘁𝗶𝗰𝗲? 🔍 Here we’ll take a closer look at a snapshot from a client due diligence (CDD) process and examine how the three lines can be utilized to enable cohesive action towards enterprise objectives. 👉 https://lnkd.in/eXbuWxaF 𝗨𝗽𝗰𝗼𝗺𝗶𝗻𝗴 𝗪𝗲𝗯𝗶𝗻𝗮𝗿 | Join us next week to learn how the three lines model applies in new and emerging areas such as digital assets. Explore the agenda and register: https://lnkd.in/e6kz6bDB

𝗪𝗵𝗶𝗰𝗵 𝘁𝘆𝗽𝗲 𝗼𝗳 𝘁𝗿𝗮𝗻𝘀𝗮𝗰𝘁𝗶𝗼𝗻 𝗶𝘀 𝗺𝗼𝘀𝘁 𝗺𝗶𝘀𝘂𝘀𝗲𝗱 𝗳𝗼𝗿 𝗶𝗹𝗹𝗶𝗰𝗶𝘁 𝗽𝘂𝗿𝗽𝗼𝘀𝗲𝘀 - 𝗰𝗮𝘀𝗵 𝗼𝗿 𝗰𝗿𝘆𝗽𝘁𝗼? The answer may surprise you. From perception to regulation, tune in to Catherine M Woods, JD to hear her take on the current challenges and solutions of evolving technologies.   𝘐𝘯𝘵𝘦𝘳𝘦𝘴𝘵𝘦𝘥 𝘪𝘯 𝘥𝘪𝘨𝘪𝘵𝘢𝘭 𝘢𝘴𝘴𝘦𝘵𝘴 𝘤𝘰𝘮𝘱𝘭𝘪𝘢𝘯𝘤𝘦? Register for our upcoming webinar to explore future challenges and trends as well as lessons learned from recent enforcement actions. 👉 https://lnkd.in/e6kz6bDB

👋 ¡Saludos desde Buenos Aires! This week, Institute for Financial Integrity's Natalie Pulsifer and Catherine M Woods, JD, Crowell & Moring's Dj Wolff, and K2 Integrity's Ladan Archin traveled on behalf of the U.S. Department of State to facilitate training for the Argentinean public and private sector. Joined by delegates from the Central Bank, Financial Intelligence Unit, and financial institutions, the two-day program focused on 𝘐𝘮𝘱𝘭𝘦𝘮𝘦𝘯𝘵𝘪𝘯𝘨 𝘚𝘢𝘯𝘤𝘵𝘪𝘰𝘯𝘴 𝘢𝘯𝘥 𝘚𝘵𝘳𝘢𝘵𝘦𝘨𝘪𝘤 𝘛𝘳𝘢𝘥𝘦 𝘊𝘰𝘯𝘵𝘳𝘰𝘭𝘴 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘙𝘶𝘴𝘴𝘪𝘢𝘯 𝘈𝘨𝘨𝘳𝘦𝘴𝘴𝘪𝘰𝘯. While Argentina complies with UN sanctions, and does not enforce U.S., UN, or EU sanctions, it has had designations of its own; just last week, Argentina designated Hamas leadership as a terrorist organization. But Argentinian authorities in attendance were supportive of their private sector's efforts to comply with U.S. and EU sanctions in order to maintain their access to $ and € correspondent banking. Key questions for discussion included: ❔What are the differences between U.S., EU, and other sanctions regimes? ❔How do ownership and control of entities influence whether they are subject to sanctions? ❔What are the key controls in protecting against sanctions evasion and export control violations? The learning doesn’t end here. All participants are registered with access to DOLFIN as well as the CRMS-RS certification program. We're honored to partner with the State Department on the delivery of this important training and want to thank our many partners in Buenos Aires for making this program a success on the ground. ⚽ It’s been a happy coincidence to experience #Argentina winning the Copa América. ¡Felicidades! 🎉

🚫 OFAC recently imposed significant new 𝗿𝗲𝘀𝘁𝗿𝗶𝗰𝘁𝗶𝗼𝗻𝘀 𝗼𝗻 𝗜𝗧 𝗮𝗻𝗱 𝗿𝗲𝗹𝗮𝘁𝗲𝗱 𝘀𝗲𝗿𝘃𝗶𝗰𝗲𝘀 𝘁𝗵𝗮𝘁 𝗨.𝗦. 𝗽𝗲𝗿𝘀𝗼𝗻𝘀 𝗰𝗮𝗻 𝗽𝗿𝗼𝘃𝗶𝗱𝗲 𝘁𝗼 𝗥𝘂𝘀𝘀𝗶𝗮. Delve into a breakdown of the new determination and implications for U.S. companies in our latest article: https://lnkd.in/evWp5J3A   OFAC’s new determination aims to hinder the Russian military’s access to the latest technologies and software, impeding Russia’s ability to conduct effective and advanced battlefield operations.   The prohibitions include bans on: 🖥 IT consultancy and design services ☁ Cloud-based services 🛠 Design and manufacturing software   Multinational tech corporations, financial institutions, and other companies still operating in Russia will likely require licenses to continue operating there.

🎞 𝘞𝘩𝘢𝘵 𝘢𝘳𝘦 𝘬𝘦𝘺 𝘱𝘳𝘦𝘷𝘦𝘯𝘵𝘢𝘵𝘪𝘷𝘦 𝘮𝘦𝘢𝘴𝘶𝘳𝘦𝘴 𝘰𝘧 𝘧𝘳𝘢𝘶𝘥 𝘢𝘯𝘥 𝘤𝘰𝘳𝘳𝘶𝘱𝘵𝘪𝘰𝘯? On our recent webinar, Millennium Challenge Corporation's Christopher P. Williams laid out effective strategies for financial institutions to detect and prevent bribery, fraud, and extortion, including key indicators to watch for and best practices for risk mitigation. Key preventative measures highlighted were: 🔹Dedicated funds and personnel to anti-corruption 🔹Clear and explicit rules forbidding fraud and corruption and requiring disclosure of conflicts of interest and reporting of potential fraud or corruption, with signed acknowledgements 🔹Use of international standards 🔹Clear posted instructions on how to report potential fraud or corruption 🔹Clear responsibility for following up on reports 🔹Real consequences (termination, debarment, prosecution) ✅ Read the key takeaways from the webinar: https://lnkd.in/eG4Umtqz 🎥 Watch the full recording: https://lnkd.in/eK5z-DDk