- 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 the Emerald Isle, Ireland, to see through the eyes of a professional with nearly five years of experience in financial crime compliance and investigations, enhanced due diligence and politically-exposed persons (PEP) screenings – and a deep well of knowledge in language, arts and history.
- Such a diverse skillset, in one case, helped tell fantasy from reality when the names of companies read like a tale from Arthurian legend – King Arthur, Excalibur and Queen Guinevere. That resulted in a quest uncovering a high-flying scheme to take supposed funds lent for mortgages to be used to buy, refurbish and resell commercial passenger planes – a much different and riskier profile.
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
April 15, 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.
This time around, we are tackling one of the most vital, and challenging, areas of fincrime 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 the Emerald Isle, Ireland, to see through the eyes of a professional with nearly five years of experience in financial crime compliance and investigations, enhanced due diligence and politically-exposed persons (PEP) screening – and a deep well of knowledge in language, arts and history.
Such a diverse skillset, in one case, helped tell fantasy from reality when the names of companies read like a tale from Arthurian legend – with names like Arthur, Lancelot and Guinevere.
That resulted in a quest that uncovered a high-flying scheme to take supposed funds lent for mortgages to be used to buy, refurbish and resell commercial passenger planes – a much different and riskier profile.
The ability to uncover, in many cases, obscure asset ties to powerful politically-exposed persons (PEPs), wealthy oligarchs and gilded gatekeepers, is a skillset that has surged in demand as countries hunt for sanctioned Russian assets after Russia’s invasion of Ukraine in February, according to government disclosures and media reports.
Thousands of Russians have since been sanctioned by the United States, the European Union, and the United Kingdom, among others, according to CNN, which has created a Russian sanctions asset tracker detailing what properties, yachts and other assets have been seized or frozen.
To view the asset tracker, click here.
So far, superyachts and multimillion-dollar properties have already been seized or frozen by authorities in Italy, France, Spain, the UK and Gibraltar, according to CNN.
The United States has also launched KleptoCapture, a task force focused on those who violate sanctions and the seizing of their assets, a move that should not be lost on fincrime compliance and sanctions teams at banks – who are on the hook for implementing the sanctions and scouring for hidden and shadowy ownership interests.
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.
So what have we learned so far in ACFCS’ first “Fincrime Compliance Career Tips and Tricks” initiative?
To grow in the fincrime compliance field, you need to expand knowledge in more areas, going beyond historic anti-money laundering (AML) and fraud mores.
Throw down the gauntlet and spearhead compliance convergence at your institution.
Be a champion who prevents investigations from running in parallel and get your fraud, AML and cybersecurity teams to connect, collaborate and speak the same language, like knights of old at the round table.
Then go further and push the knowledge and skills across fincrime compliance disciplines to the frontline and beyond – extend deep and relevant training to your business line and frontline tellers, and even to customers.
But don’t forget about growing on an individual level.
To compete in the physical and virtual financial worlds, drill down to more complex and nuanced areas, like crypto and data analytics – crafting a unique and in-demand skillset that prepares you not just for where the industry has been and where it is now, but where it is going.
Fincrime professionals, including current and former compliance officers, regulators and investigators, also highlighted the need to be part of a community.
In short, it is absolutely critical to network 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.
Now, on to fresh tips to hone your skills as an investigator.
Name: Eamonn Cotter
Organization: Novi Financial
Title: Compliance Specialist
What are the top two or three most important investigative skills you have learned in your career?
1) Critical Thinking – it’s similar to Design Thinking that I got when I was in college.
2) Being able to spot patterns – across multiple industries and among the different types of customers.
3) Being able to investigate and find key pieces of information from multiple sources that help with determining true/false positives.
What is your advice to someone who wants to improve the efficiency, effectiveness, depth and/or timeliness of investigations?
Find out what information are facts (e.g. through a customer’s ID) and what information was true when onboarding or when the account was last updated – and that it may have changed since.
One example would be, for instance, that the customer is down as college student, but it hasn’t been updated for over a decade.
Then do the same to whatever has triggered the investigation.
Sorting fact from fiction is important and finding out what information is relevant to the case and what can’t be trusted.
What technologies and/or information sources do you typically use in an investigation (e.g. internal or external, OSINT, bespoke, etc.)?
I love FlightAware – a fantastic airplane tracker for both investigators and as citizen.
It tells you where your plane is at any giving time, including speeds and altitude – and beneficial ownership.
It comes in handy if you want to know what gate the plane is at, before the airport tells you.
It even tells you when the plane has landed before it’s announced elsewhere. It also gives a map of the world with every aircraft in real time.
What are the biggest challenges or pitfalls to avoid when trying to conduct an effective investigation?
Using websites that could be manipulated or edited without cross-referencing to factual information – like LinkedIn is a great source for giving an idea – but it can be faked.
Wikipedia is more reliable as it’s proofread more often than any LinkedIn account.
What is an example or case study about an investigation that surprised you?
[Some details had to be changed to anonymize this example] I became aware of an instance where a financial institution had a lot of company accounts that had strange names in themes like Princess Guinevere, Lancelot Knight, Avalon Camelot, King Arthur or Green Emerald Seven, Gleaming Emerald Five.
Mortgages were being given and paid rapidly, but no one in the head office really understood what the business did.
After several weeks of investigations, it was uncovered that the mortgages were actually loans to buy airplanes which would be refurbished and then sold/leased to some of the biggest European airlines.
When the findings were presented to institution management, those involved reportedly joked that when a plane went by, they would say, there went the “King Arthur” Mortgage flying by.
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.