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Blue Square Global asset based finance industry MLRO presentation
1. Lending or laundering? Business Financing or
Terrorist Financing?
Presented by Jim Stothard
Director of Financial Crime and Risk
Blue Square Global
2. Presentation content
The fine line between lending or laundering, business financing or terrorist financing.
Horizon Scanning.
Examples of best practice.
Credit Risk vs Conduct Risk.
Fraud and Terrorist Financing come hand in hand.
The governments proposed new laws to hold companies responsible for fraud.
3. • Take a risk based approach for prevention of money laundering and terrorist financing.
• Ensure your due diligence is ‘non vanilla’
• More emphasis on quality over quantity.
• Well evidenced decision making.
• Get the balance right between TCF and Financial Crime detection. Fair and robust.
• Conduct good thorough due diligence at the client onboarding stage.
• Regularly review your fraud prevention processes through good MI, monitoring and horizon
scanning.
• Use the right independent consultants with a background in fraud prevention and criminal
investigations.
What does good look like?
4. • Money laundering through over- and under-invoicing of goods and services is one of the
most commonly used methods for laundering funds across borders.
• By invoicing a product or service below market value, an exporter can shift funds to the
importer because the payment to the exporter is less than the value that the importer
receives when the goods are sold at market value.
• by invoicing a product or service at a price higher than market value, the exporter
transfers value from the importer. That’s because the payment to the exporter is greater
than the value the importer receives when the product or service is sold at market
value.
• complex products and products that travel through supply chains with reduced paper
trails are more apt to be used in these types of over- and under-invoicing activities
because they complicate the ability of customs officials to determine the true market
value of such goods and services.
Understand the methodology
5. • An MLRO subscription helpline where you can speak to one of our AML Subject Matter
Experts and discuss any concerns and seek guidance on whether to report or not, how
to structure the suspicious activity report and how to ensure best practice.
• Review of your AML / CTF/ ABC policies and controls.
• Remediation Projects including KYC and KYC refresh.
• Market leading AML and fraud detection technology blended with subject matter
experts.
• Financial Crime Investigations and debt recovery.
• Fraud Risk Reviews.
How we can support you
6. • Damian Ozenbrook – Chief Executive Officer
• Jim Stothard – Director of Financial Crime and Risk
• Julie Wiggs – Director of Investigations and Due Diligence
Our Leadership Team