In quest to capture data, conquer corporate ownership registry challenges, Moody’s Analytics’ Ljubinka Slaveska gets ‘absorbed’ into AML world

By Brian Monroe
bmonroe@acfcs.org
May 18, 2022

Call it destiny. Call it being on an inexorable path. In her own words, Ljubinka Slaveska calls coming into the compliance field – or rather it absorbing her for its own countercrime purposes – an accident, but no doubt a very fruitful one.

While maybe not aware of it at the time several years ago, Slaveska – who joined Moody’s Analytics in 2022 after more than a decade wrestling with the complexities of capturing, analyzing, cataloguing, sharing and updating business registry data – had set herself on a path to tackling one of the biggest financial crime challenges of the modern era.

While she was working to update and digitize corporate ownership registries in Macedonia, countries like the European Union, United Kingdom, United States and others were also working on similar initiatives.

The tacit goal: find a way to prevent organized criminal groups, corrupt political powerbrokers, cyber-enabled fraudsters and others from using lax incorporation rules to hide behind shell companies and launder money.

In fact, she jokes that going back a few years, when someone mentioned the word “compliance,” she imagined groups endlessly agonizing over arcane rules and stuffy regulations, a far cry from her background as an outgoing, outspoken professional with a deep background in strategic communications.
“I never thought for one second that I would ever be part of the AML landscape,” Slaveska said. “I considered compliance tedious and monotonous work that wasn’t cut out for my skills and personality.”

Out of college, she envisioned herself doing communications or public relations, a role she performed well when she joined the Macedonian Central Register in 2011.
But in doing PR for a new corporate ownership digitalization program, Slaveska became more interested and intrigued by the “registry’s role, what problems it’s set up to solve, and how it is expected to serve the business community and the government.”

That understanding and desire to learn grew even more a few years later when she got involved in the work of the international business registers associations, coming to the realization that “registries worldwide face similar issues and are trying to solve common problems,” she said.

In quest to uncover domestic, international corporate ownership data, an AML ally emerges

At the same time as her knowledge grew about registry challenges, she started to see a crossover between the risk and technology needs of AML teams to better find and report on risky regions, businesses and ties to potential illicit finance.

She was at a global registry conference in Cardiff in 2016 when top minds in the space formed a working group on the establishment of registers of beneficial owners in response to new EU rules.

In those discussions Slaveska’s eyes were opened to reconsider the business register’s role as a “key player in the core AML infrastructure. Being part of the core team to set up the register of beneficial owners in my registry was my leeway into the AML milieu,” she said.  

“It was through the extensive and thought-provoking discussions with the financial intelligence unit, the national bank, financial institutions, notaries, lawyers, and accountants, and through collaboration with registry peers across Europe and the world, that I learned details about exactly how powerful company data is in the AML context.”

That knowledge became a passion and that passion became a mission to help fincrime fighters around the globe.

“At that point, I felt a sense of responsibility to work toward leveraging technology and global collaboration to support the anti-money laundering efforts,” she said. “I ended up where I am by accident. Turns out, the AML field absorbs and provides purpose and meaning for many different profiles, skills, and backgrounds.”

As well, Slaveska’s unique background of expertise crafting and merging ownership registries – including across multiple jurisdictions – was a perfect fit for Moody’s Analytics.

She has vast expertise in beneficial ownership registration, registry e-services, national and cross-border company data interoperability and registry data distribution models and mechanisms.

Currently, Slaveska is the Senior Regulatory Manager at kompany, part of Moody’s analytics, leading a team responsible for the live connections to more than 100 business and beneficial owner registers.

When all are one: Centralizing corporate ownership data can empower AML teams

Such broad and timely access to what is typically disparate beneficial ownership details spread across jurisdictions, data types, access parameters and restrictions, allows users immediate access to fresh corporate data.

Not surprisingly, this is a coveted treasure trove of risk divination, investigations and reporting information for AML teams.

Over the past decade, regulators have handed down billions of dollars in penalties to banks and other financial services firms for failings in AML, sanctions and anti-corruption programs – in part because they didn’t accurately risk rate clients and didn’t realize more obscure illicit connections behind crooked corporations.

The challenges in accurately engaging in AML risk rating, monitoring and reporting on customers – individuals and businesses – is one of the reasons Moody’s Analytics is a multi-billion-dollar subsidiary of household-name ratings powerhouse, Moody’s Corporation.

Moody’s established the analytics arm in 2007 to focus chiefly on non-rating activities, rather than its historical core mission of better arming investors.

In all, Moody’s Analytics provides economic research regarding threat intelligence, performance expectations and financial modeling, as well as consulting, training and software services, including in the arena AML risk analysis, management and reporting.

For some countries, lax ownership information isn’t a drawback, it’s a selling point

For many countries, weak or even no requirements to divulge real flesh-and-blood owners isn’t a detriment or accident – it’s a selling point.

Criminals and tax evaders are in a near constant search to shield, move and hide funds, looking for the path of least resistance – or at least path of least scrutiny.

The countries advertising such services can reap a massive financial windfall, both from criminals or the wealthy willing to part with their scruples.

When it comes to the perils of impenetrable ownership structures and financial secrecy, Slaveska also has firsthand knowledge, working as a research collaborator for nearly a year crafting the Tax Justice Network’s Financial Secrecy Index in 2022.

The index, first published in 2009, is an annual ranking of countries “most complicit in helping individuals to hide their finances from the rule of law.”

The index spotlights the laws and policies that governments can change to reduce their contribution to global financial secrecy, which is also a magnet to criminal groups of all stripes, according to the group.

Overall, an “estimated $10 trillion is held offshore beyond the rule of law by wealthy individuals through secretive arrangements” – more than twice the value of all US dollar and EURO bills and coins in circulation around the world.

It is numbers like those that fuel Slaveska's passion to overcome the many challenges to uncover corporate ownership data, centralize it in a register and better arm companies to prevent being victimized by creative criminal groups.

“The goal is to expand and enhance our primary source network so that we can provide stable, automated access to company data globally via a single gateway,” she said. “Just think for a second about how powerful that is.”

“In the context of fighting financial crime, the problems we are solving with this range from seemingly trivial sign-in and paywall issues that one would need to handle to access various registers, to major efficiencies that free up compliance professionals to focus on complicated and high-risk cases.”

It is a powerful turnaround for Slaveska in her career, going from not being able to understand the AML world to enabling their fight by shining a light in dark corporate corners.

"In a nutshell, we see our role as enablers for professionals who fight financial crime,” she said.

Slaveska was kind enough to share some of her knowledge and insight in our latest ACFCS Member Spotlight:

Who inspires you?

I try to find inspiration intrinsically. I start and end days with a drive to contribute – to the team, clients, and the industry.

I try to learn, relearn and be better so I can bring more value. In that vein, I am continuously inspired by people from all walks of life who consciously decide to go the extra mile beyond what is required or expected – the teacher, the waiter, the manager, the team member…

What is one thing – either industry-related or not – that you learned in the past month?

Very random – I learned how carbon capture works and realized the promise it holds.

All our efforts to reduce our carbon footprint seem to be insufficient, so I place hope in the brilliant minds behind these technologies.

What is something about you that not many people know?

I really don’t like being labeled or [ people being] put into boxes. I think I have a biological reaction to this. I truly feel that individuals are multidimensional and classifications create artificial divisions.

Also, I am very unsophisticated and boring when it comes to food. I like my meat well done, never tried sushi, and would have pizza every day if I didn’t feel the pressure to set a good example for my sons.

What do you do in your current role?

I am responsible for a team that works at the intersection of regulatory compliance and technology.

Our main job is to identify regulatory requirements around primary source data for AML-related legal entity verification and then secure smooth live access to those sources to be able to retrieve company data in real-time.

Then we essentially make sense of the data and normalize it without jeopardizing its integrity.

The goal is to expand and enhance our primary source network so that we can provide stable, automated access to company data globally via a single gateway.

Just think for a second about how powerful that is.

In the context of fighting financial crime, the problems we are solving with this range from seemingly trivial sign-in and paywall issues that one would need to handle to access various registers, to major efficiencies that free up compliance professionals to focus on complicated and high-risk cases.

Seamless automated access to structured primary source data and the required documentary evidence, augmented with automatic monitoring of changes, sanctions screening, and cross-border shareholder discovery constitutes a very powerful tool financial crime professionals can confidently rely on.

So, in a nutshell, we see our role as enablers for professionals who fight financial crime.

Now, where it all gets juicier, and what in essence makes us a RegTech company, is the amazing cutting-edge technology that is being built, continuously enhanced, and optimized in the background to make all this happen.

Registry data comes in all sorts of shapes and sizes, and registries around the world operate on varying technology platforms – so putting it all together and making it work seamlessly through a single gateway is some serious magic made possible by some very talented people.

What does your career trajectory in financial crime look like?

In simple terms, I am a product of the global business registry community – influenced, supported, challenged, and mentored by some seriously outstanding people leading resilient institutions and high-performing teams through extremely turbulent times.

Out of university, I always thought I would do communications and public relations, and that’s what I did even when I joined the Macedonian Central Register in 2011.

The register seemed like a challenge from a strategic communications perspective as it was about to embark on a major digitalization program that needed a lot of outreach and proper communication tailored to specific audiences.

This type of involvement provided me with a holistic view of the registry’s role, what problems it’s set up to solve, and how it is expected to serve the business community and the government.

Then, a few years in, I also got involved in the work of the international business registers associations, and that’s how I learned that registries worldwide face similar issues and are trying to solve common problems.

It was at a global registry conference (yes, those exist!) in Cardiff in 2016 when a working group was formed to tackle the establishment of registers of beneficial owners in response to EU regulation.

It was around this time that registry leaders’ eyes were opened to reconsider the business register’s role as a key player in the core anti-money laundering (AML) infrastructure.

Being part of the core team to set up the register of beneficial owners in my registry was my leeway into the AML milieu.

It was through the extensive and thought-provoking discussions with the financial intelligence unit, the national bank, financial institutions, notaries, lawyers, and accountants, and through collaboration with registry peers across Europe and the world, that I learned details about exactly how powerful company data is in the AML context.

At that point, I felt a sense of responsibility to work towards leveraging technology and global collaboration to support the anti-money laundering efforts.

I say this with humility, since I understand that access to official company data is just scratching the surface of financial crime investigations. But this is exactly why I think all friction at this stage needs to be removed, and I am thrilled to be able to make that happen in my current role.

What is the best advice you have ever received?

“Choose your battles.”

This one is still difficult for me. I have to keep reminding myself that I need to let go of some things along the way in favor of the big picture of the desired end goal.

“Surround yourself with people who are different from you.”

I feel like the importance of this cannot be overestimated.

When life throws at you your polar opposite – make the best of it. I feel like I’ve made leaps in my personal and professional development in situations where I’ve worked with people who think, speak, and look differently.

What is the worst advice you have ever received?

“Don’t fix it, if it ain’t broken.”

I’ve always been fixated on efficiencies, both personally and professionally. I always look for ways to improve processes and outcomes.

What would you say are the most important attributes for someone in your role to be able to succeed?

• Communication skills, however much cliché that may sound.

One must be able to relay complex concepts in simple and straightforward terms at multiple points on a daily basis.

You have to be able to speak clearly, listen attentively, write well, summarize effectively, ask the right questions, adapt to different people, make your case tactfully, and rally supporters.

I believe a continuous investment in developing communication skills is highly worthwhile.

• Equally important, I would underline the notion of “situational awareness.”

Be attentive to the news, know what’s going on, and try to understand the wider context, whether it be political, geopolitical, financial, or otherwise. Be curious, think critically, try to make analogies, and connect the dots. Have a bird’s-eye view.

• Don’t be intimidated by data.

I am surprised to see that many people are. Deep dive – analyze, question, make sense of it, figure out similarities and differences, and understand its limitations. Ask for help if you need to. Be data literate.

How has (compliance, investigations, etc.) changed and evolved during your career?

I joined the Macedonian Central Register on a mission to increase engagement with the then-emerging registry e-services both for filing and retrieving data and documents.

At the time, we had to educate people where to click to get a document, but we also had to educate banks, courts, and the like that an electronically issued and signed document by the register is equally as legally valid as a document that is signed, sealed, and delivered in paper form.

We have come a long way in 10 years – we are witnessing registry extracts and various types of certificates becoming obsolete, as users are increasingly expecting to get the data automatically into their systems or look it up online, even on their phones.

Take the issue of physical addresses, as well. Addresses are a key element of know-your-customer (KYC) entity verification, both for onboarding and monitoring.

However, businesses are increasingly operating fully online, with all documentation in digital form, so how much value does collecting street addresses bring? For what is this data point useful?

We’ve also seen a major effort towards institutional interoperability – both national and international, both on the filing and the data distribution side.

Be it driven by the so-called “once-only” principle to reduce red tape, by attempts to increase data quality and currency, or by trying to service an increasingly interconnected and global economy – interoperability holds a lot of promise and is yet to be implemented to its full potential.

Doing business, and with that money laundering risks, never knew of national boundaries, but this has been multiplied to the nth degree in the past decade.

We see complex ownership structures spanning multiple countries, cross-border transactions, and instant payments. This has brought about a need for institutions and service providers to regroup and adjust their approach and adapt or upgrade their tools and internal methodologies.

During this time, business registries have become the backbone of the digital economy and a key enabler of the global response against money laundering.

The persona of a registry user has largely evolved, driven by both technology and regulation. Registries have had to find ways to optimize how they collect and verify data, as well as how they make the data available.

The need for perpetual KYC in the fight against financial crime, for example, makes monthly bulk files and individual searches on registry portals inadequate. The new context requires automated retrieval of structured data, via web services with no manual intervention.

Many of the registries have caught up, and for many, this is still a work in progress.

I have had the privilege to be part of this shift, and I continue to be “the voice of the user” in conversations with registers. I think I will always be a registry person at heart.

What do you see as the key challenges related to financial crime in your role or in the sector overall?

We are continuously engaging with registers to elaborate and discuss the regulatory compliance use case for registry data.

“Regulatory use” is still not fully defined and acknowledged uniformly globally. This falls between “own use” and “commercial use.”

We discuss the specificities of the use case, as well as the assurances that we provide around the accountability related to the use of the data. We build partnerships with the registers, as we are their extended arm.

We still see some bizarre restrictions around accessing registry data, for example, geoblocking, so it is our responsibility to engage with the registers to point these out when we come across them.

What motivated you to become a financial crime professional?

I never thought for one second that I would ever be part of the AML landscape. With a strategic communications background, I considered compliance tedious and monotonous work that wasn’t cut out for my skills and personality.

I ended up where I am by accident. Turns out, the AML field absorbs and provides purpose and meaning for many different profiles, skills, and backgrounds.

Is there anything that surprised you about your current role?

Oh, that’s easy. That not many people share my level of passion for registries and company data, haha.

What is the most rewarding part of your job?

There is a thrill in being ahead of the market. It feels like you are creating the future. On a basic level, though, it’s amazing to see people thrive and grow. The most rewarding part is the visible progress – of the offering, the team, and myself.