Posted by Brian Monroe -
The skinny:
- In this initiative, ACFCS is engaging the fincrime compliance community for wisdom and practical insights on how to build, broaden and sharpen your investigative toolkit with the goal to become a more effective investigator.
- For this tip, we travel to Norway, where a professional with a deep wealth of experience in fincrime compliance and sanctions investigations offers critical guidance to be a more focused, results-driven detective.
- How? By asking better questions and challenging the answers you are given. Try to find the most relevant information through the highest sources – not just what the client gives you and where the individual tries to steer inquiries.
This Fincrime Career Investigative Tips and Tricks is part of the association’s new Community Collaborations series, to share the top tips, tactics and techniques to conquer compliance.
By Brian Monroe
bmonroe@acfcs.org
March 21, 2022
In this initiative, ACFCS is engaging the fincrime compliance community for wisdom and practical insights on how to build, broaden and sharpen your investigative toolkit with the goal to become a more effective investigator.
Among the biggest questions ACFCS Members ask and want answers to are: What will the regulators be doing next, how do I enter and rise in the fincrime compliance field and how do I become a better investigator across the full spectrum of financial crime.
That is why for the association’s first Tips and Tricks initiative, we asked members how they broke into the fincrime compliance world and what were some of their secrets to success.
Some of the responses included advice to expand knowledge in more areas, going beyond historic anti-money laundering (AML) and fraud mores, to spearhead compliance convergence, but also drilling down to more complex and nuanced areas, like crypto and data analytics – crafting a unique and in-demand skillset.
Fincrime professionals, including current and former compliance officers, regulators and investigators, also highlighted the need to be part of a community, including networking in and out of your institution to see bank countercrime challenges through the eyes of other departments – and gain access to deeper and broader insight from top industry thought leaders.
This time around, we are tackling one of the most vital, and challenging, areas of AML compliance: what are the knowledge areas and skills needed to engage in relevant, timely and effective investigations that truly support law enforcement.
For this tip, we travel to Norway, where a professional with a deep wealth of experience in fincrime compliance and sanctions investigations offers critical guidance to be a more focused, results-driven detective.
How?
By asking better questions and challenging the answers you are given. Try to find the most relevant information through the highest sources – not just what the client gives you and where the individual tries to steer inquiries.
Further, after you have triangulated multiple sources in and out of the bank, pull back the investigative lens by making a quick check of related parties on social media.
The reason: a criminal might be savvy enough to fool standard AML checks, but their spouses or children might give up the goods – in one case, a luxury yacht.
The strategies the wealthy, elite and, in many times, corrupt, have taken to launder money and hide connections to opulent mansions and gold-plated yachts have captured the world’s focus with the United States, United Kingdom, Europe and even the typically neutral Switzerland targeting Russian oligarchs after the country invaded Ukraine.
The yachts and their billionaire owners, many of which are among Russian President Vladimir Putin’s closest allies, were included in a series of sweeping global sanctions recently imposed against Russia for its invasion of Ukraine, according to government statements and media reports.
In recent weeks, Italy seized a $578 million megayacht belonging to Andrey Melnichenko, France seized a $120 million vessel owned by Igor Sechin, and Spain seized a $153 million superyacht linked to Sergei Chemezov, according to Business Insider.
Name: Nick Litvinenko
Organization: PwC
Title: Manager, FinCrime and Sanctions Compliance
Country: Norway
What are the top two or three most important investigative skills you have learned in your career?
1. Triangulation and interview methodology.
2. Underlying knowledge of criminology and legislation within financial crime and sanctions.
3. Skepticism to any sources of information.
What is your advice to someone who wants to improve the efficiency, effectiveness, depth and/or timeliness of investigations?
1. Create a few fact-based hypothesis.
2. Collect facts and evidence from various non-related sources.
3. Try to test and disprove the hypotheses.
4. Limit the scope in your assessment to very concrete events you want to prove.
What technologies and/or information sources do you typically use in an investigation (e.g. internal or external, OSINT, bespoke, etc.)?
Interviews
Financial data and reporting
OSINT
Human source inquiries
Digital footprint analysis
Subject matter expertise to rule out wrongful evidence provided by the interviewees
Regulatory comments and opinions, litigations
What are the biggest challenges or pitfalls to avoid when trying to conduct an effective investigation?
Trying to chase all hypotheses, collecting all possible information without focusing on the most relevant information (requires assessments), talking to people without knowledge (requires assessment prior to interviews), bad investigation plans, spending too much time in group discussions (albeit they are important if conducted from time to time).
What is an example or case study about an investigation that surprised you?
An individual we were investigating tried to launder funds through various transfers initially leading to a purchase of a luxury yacht, which just popped up on the Instagram account of his wife.
These kind of events are not uncommon – many of the suspects can be strong in one field which they try to exploit in a criminal way, and completely incompetent in others.
Get involved in sharing your investigative tips: How It Works
Each quarter, ACFCS is asking its members for advice on various aspects of fincrime careers, from getting your foot in the door to finding a mentor and more.
This quarter, we’re focused on tips, tricks and guidance engaging in deep, relevant and effective investigations.
We want to capture everything from the most important investigative skills and how to sharpen them to the biggest challenges professionals face daily in the trenches – and human and technology tactics to overcome them, along with some bonus case studies that taught valuable, even surprising lessons.
We’ll gather responses and share them back with our member community. Three participants will receive one year of complimentary ACFCS members (added to your existing membership for current members).
To learn more and submit your tips, click here.