AML CFT Compliance


An International Anti-Corruption Day……ever heard of it? What is the point of this day though? What do we expect to accomplish with an International Anti-Corruption Day? Do you as a Compliance Officer know anything about this international day? How important is corruption for you as a Compliance Officer? Let’s take a further look, shall we?


Transparency International defines corruption as the abuse of entrusted power for private gain. Corruption erodes trust, weakens democracy, hampers economic development, and further exacerbates inequality, poverty, social division, and the environmental crisis.

The United Nations UNODC defines corruption as a complex social, political, and economic phenomenon that affects all countries. Corruption undermines democratic institutions, slows economic development, and contributes to governmental instability. Corruption attacks the foundation of democratic institutions by distorting electoral processes, perverting the rule of law, and creating bureaucratic quagmires whose only reason for existing is the soliciting of bribes. Economic development is stunted because foreign direct investment is discouraged and small businesses within the country often find it impossible to overcome the “start-up costs” required because of corruption.

Apart from raising awareness against the crime, the aim of the anti-corruption day is also to actively support campaigns that combat and prevent corruption. Through this day, the UN also seeks to support international cooperation to fight against corruption.

Corruption and AML- CFT

Corruption and money laundering are intrinsically linked. Corruption offences, such as bribery or theft of public funds, are generally committed for the purpose of obtaining private gain. Money laundering is the process of concealing illicit gains that were generated from criminal activity.

The FATF Recommendations were designed to combat money laundering and terrorist financing, but when effectively implemented they can also help combat corruption, by:

  • safeguarding the integrity of the public sector
  • protecting designated private sector institutions from abuse
  • increasing transparency of the financial system
  • facilitating the detection, investigation and prosecution of corruption and money laundering, and the recovery of stolen assets.
  • availability of beneficial ownership information. Countries need to make sure that up-to-date and accurate information is rapidly available to authorities so we can stop anonymous shell companies laundering funds.
  • increase oversight of the non-financial sectors. The gatekeepers to the financial system – such as lawyers, accountants, and company service providers – need to be inside the regulatory tent so law enforcement agencies have relevant information to build cases.

Cost of corruption

Political costs, freedom and rule of law.
Social costs, participation and trust in government.
Environmental costs, chance for a healthy environment and a sustainable future.
Economic costs, opportunity to build and grow wealth.

Use the word ‘my’ after every cost and see how it feels to you. Tell me whether you are going to consider corruption only while dealing with your PEP clients at work, or whether you will start considering how important and relevant this topic is for you, your family, and your community….

Further reading:

Money Laundering from Environmental Crime

This article has been written in a personal capacity.


A Blog about AML-CFT Compliance? Sure! Let’s talk about AML-CFT Compliance together. Let’s discuss the laws, the work, the entities, our colleagues, our regulators, ourselves and AML-CFT Compliance. This blog serves to inform, educate, share, discuss and empower all Compliance Officers, aspiring Compliance Officers, happy Compliance Officer and those struggling with the weight of their work and responsibilities in an ever-growing community of more and more pressure to comply……

Money Laundering from ENVIRONMENTAL CRIME

Have you heard of this one before? Is this even a thing? Is this a ‘ver van mijn bed show’? Why bother if we are not even as far as understanding our own national ML, TF risk to be concerning ourselves with environmental crime! There is too much going on, I don’t have time to read, understand nor inform myself about what’s happening in AML CFT Compliance outside of my jurisdiction!

Which ever one of the above you are, let me draw your attention to this topic:

Environmental crime is one of the most lucrative criminal activities, generating
around USD 110 to 281 billion in criminal gains each year. Environmental crime has far-reaching impacts beyond the financial cost, including for the planet, public health and safety, human security, and social and economic development. It also fuels corruption, while converging with other serious crimes such as drug
trafficking and forced labor.

Specific examples of environmental crime:

  • Animal poaching, such as illegal capturing or killing for body parts
  • Animal smuggling, such as the trafficking of ivory or rhino horns
  • Production of hazardous waste
  • Pollution of the atmosphere, oceans, rivers or earth
  • Illegal or unreported fishing
  • Illegal logging
  • Illegal mining


Criminals often rely on cash intensive sectors (frequently linked
to the export sector) and trade-based fraud to launder proceeds from environmental crimes. In the case of illegal logging and illegal mining, countries identified a heavy reliance on front companies located in offshore centres, third party transactions and complicit intermediaries (lawyers, refiners) to both conceal payments and launder gains.

Environmental Crime Red Flags

  • Corporate deception, environmental criminals may set up shell companies to handle shipping for illegal goods. Shell companies may have obscure beneficial ownership, overly complex infrastructures or be located in tax havens.
  • Transaction patterns, environmental criminals may engage in irregular or inconsistent transaction patterns, transact in amounts that don’t match the scale of their stated business or transact with high-risk countries and environmental crime hotspots.
  • Cash transactions, by dealing with cash, environmental criminals may be able to operate with a greater degree of anonymity. Entities should be on the lookout for a high frequency of cash transactions or requests for high denomination bank notes.
  • Shipping, criminals may seek to avoid AML checks when transporting the products of environmental crimes by faking, failing to complete or manipulating shipping documents.
  • Unknown goods, environmental crimes often involve exotic animal species or rare substances. Employees of financial institutions may not be familiar with these species and substances or may not even be aware of laws restricting their trade.
  • Adverse media categorization, involvement in adverse media is an important indicator of money laundering risk linked to environmental crimes.

Further reading:

New Anti Anti-Money Laundering Services for Crooks

Article by i-AML

A new dark web service is marketing to cybercriminals who are curious to see how their various cryptocurrency holdings and transactions may be linked to known criminal activity. Dubbed “Antinalysis,” the service purports to offer a glimpse into how one’s payment activity might be flagged by law enforcement agencies and private companies that try to link suspicious cryptocurrency transactions to real people.



“Worried about dirty funds in your BTC address? Come check out Antinalysis, the new address risk analyzer,” reads the service’s announcement, pointing to a link only accessible via Tor. “This service is dedicated to individuals that have the need to possess complete privacy on the blockchain, offering a perspective from the opponent’s point of view in order for the user to comprehend the possibility of his/her funds getting flagged down under autocratic illegal charges.”

The ad continues:

Some people might ask, why go into all that? Just cash out in XMR and be done with it. The problem is, cashing out in Monero raises eyebrows on exchanges and mail by cash method is sometimes risky as well. If you use BTC->XMR->BTC method, you’ll still get flagged down by our services labelled as high risk exchange (not to mention LE and exchanges). Our service provides you with a view from LE/exchange’s perspective of things (with similar accuracy, but quite different approach) that provides you with basic knowledge of how “clean” your address is.”

Tom Robinson, co-founder of blockchain intelligence firm Elliptic, said Antinalysis is designed to help crypto money launderers test whether their funds will be identified as proceeds of crime by regulated financial exchanges.

“Cryptoassets have become an important tool for cybercriminals,” Robinson wrote. “The likes of ransomware and darknet markets rely on payments being made in Bitcoin and other cryptocurrencies. However, laundering and cashing-out these proceeds is a major challenge.”

Cryptocurrency exchanges make use of blockchain analytics tools, he said, to check customer deposits for links to illicit activity. By tracing a transaction back through the blockchain, these tools can identify whether the funds originated from a wallet associated with ransomware or any other criminal activity.

“The launderer therefore risks being identified as a criminal and being reported to law enforcement whenever they send funds to a business using such a tool,” Robinson said. “Antinalysis seeks to help crypto launderers to avoid this, by giving them a preview of what a blockchain analytics tool will make of their bitcoin wallet and the funds it contains.”

Each lookup at Antinalysis costs roughly USD $3, with a minimum $30 purchase. Other plans go as high as $6,000 for 5,000 requests.

Robinson says the creator of Antinalysis is also one of the developers of Incognito Market, a darknet marketplace specializing in the sale of narcotics.

“Incognito was launched in late 2020, and accepts payments in both Bitcoin and Monero, a cryptoasset offering heightened anonymity,” he wrote. “The launch of Antinalysis likely reflects the difficulties faced by the market and its vendors in cashing out their Bitcoin proceeds.”

Elliptic wasn’t impressed with the quality of the intelligence provided by Antinalysis, saying it performs poorly on detecting links to major darknet markets and other criminal entities. But with countless criminals now making millions from ransomware, there is certainly a vast, untapped market for services that help those folks improve their operational security.

“It is also significant because it makes blockchain analytics available to the public for the first time,” Robinson wrote. “To date, this type of analysis has been used primarily by regulated financial service providers.”

That may not be entirely true. Nick Bax is an independent expert in tracing cryptocurrency transactions, and he said it appears Antinalysis may be little more than a clone of AMLBot, an anti- anti-money laundering intelligence service that first came online in 2019.




“It looks almost identical to the cheap version of AMLBot,” Bax told KrebsOnSecurity. “My guess is they’re just white-labeling that.”

Bax said a lookup at AMLBot on the virtual currency address used in the sample provided by Antinalysis shows a near identical result. Here’s AMLBot’s result for the same crypto analysis performed by Antinalysis in the screenshot at the top of this story:




“If you look at the breakdown the percentages are all almost identical,” Bax said. “I use AMLBot occasionally for good and righteous purposes. And it could also be useful for people who are just selling stuff online to make sure they aren’t receiving tainted funds.”


How FATF unwittingly helps governments target critics

Article by Angus Berwick

In late 2020, when Ugandan President Yoweri Museveni faced a fresh challenge to his 35-year rule, a new tool helped to silence his critics: anti-money laundering legislation promoted by the G7.

The Financial Action Task Force, established by the G7 group of advanced economies to protect the global financial system, had written to Uganda’s government eight years earlier telling it to do more to combat money laundering and terrorism financing or risk being placed on a “grey list” of deficient countries, according to a top Ugandan official who described the private letter to Reuters. Such a move could damage Uganda’s ties to foreign banks and investors, which closely follow the FATF’s updates.

Within a year, Uganda’s parliament passed a new law to criminalize both offences and established an intelligence unit to enforce it.

But Uganda didn’t deploy the law as the FATF intended.

Last December, as Museveni prepared for a January election, authorities used the law to temporarily freeze the bank accounts of three rights groups and arrest a prominent lawyer, 40-year-old Nicholas Opiyo, on money laundering charges related to the funding of an NGO he founded. Opiyo, who was later released on bail, called the charges “spurious.” The government has denied using the law to target its critics. In January, amid accusations of voter fraud by Museveni’s main rival, the electoral commission declared Museveni had won re-election.

Uganda isn’t unique.

Reuters found that in at least four other countries – Serbia, India, Tanzania, and Nigeria – legislation passed to meet FATF standards was used by authorities to investigate journalists, NGO workers, and lawyers. Based on interviews with people targeted, government officials and financial crime experts, the reporting by Reuters provides the first account of the unintended consequences arising from the task force’s mandate.

Through constant assessments of countries’ measures, the FATF plays a little-known but key role in shaping financial crime legislation and in dictating governments’ security priorities. Across the globe, it has strengthened laws to crack down on money laundering and terrorist financing. But by pressuring nations with weak democratic frameworks to adopt and bolster such laws, the FATF has unwittingly handed a new legal instrument to authoritarian governments, according to a dozen researchers at think tanks and human rights groups.

“Its standards are increasingly not just being misunderstood, but are being purposefully abused,” said Tom Keatinge, director of the Centre for Financial Crime at the Royal United Services Institute in London.

In particular, a focus at the FATF from the early 2000s on tackling terrorist financing through non-profit organizations has allowed some governments to pursue legitimate civic groups under the cover of enforcing international standards, according to researchers. “Non-profit organizations can get caught in those crosshairs,” said Tracey Durner, a director at the Global Center on Cooperative Security in New York.

The FATF, in emailed responses to Reuters’ questions, said it was aware of reports its recommendations have been misused and was monitoring governments’ oversight of nonprofits. It said this year it established a working group on the “unintended consequences of poorly implemented” measures and was identifying possible options to mitigate them.

“Any misapplication of the FATF Standards in a way that suppresses the legitimate activities of non-profit organisations or curtails the human rights of individuals is clearly a matter of grave concern and cannot be condoned in any way as part of the fight against money laundering and terrorist financing,” it said.

Asked about the warning letter sent in 2012 to Uganda’s then finance minister, Maria Kiwanuka, the FATF said it “does not comment on private correspondence with governments.” Kiwanuka, who was replaced in 2015, told Reuters she received letters from many different parties and referred comment to the finance ministry, which did not respond to emails.

Uganda’s top anti-money laundering official, Sydney Asubo, who reviewed the letter at the time, said Opiyo’s arrest was a police matter and declined to comment on the merits of the case.

Asubo defended the government. “We are doing what is required by the FATF,” he said.

Terrorist financing experts consulted by Reuters said the FATF has limited the funding of groups like al Qaeda by making banks more risk averse and giving authorities more powers to investigate an entity’s finances. However, they faulted the task force’s blanket approach to improving standards because it fails to take into account the political motivations of governments and the risk of misuse of the rules. Since last year, Turkey and Myanmar – countries where authorities have jailed journalists and democracy advocates – have introduced new legislation and procedures to meet FATF standards which enable authorities to seek more financial information from NGOs.

De ontwikkelingen binnen de juridische technologie

Artikel van Terren Chong

Waar ter wereld uw werkplek zich ook bevindt u ontkomt er niet aan: regels. Als jurist weet u als geen ander hoe belangerijk het is om de regels te kennen. Wekt u in een digital omgeving – wie doet dat niet tegenwoordig? – dan gelden daarvoor specifieke regels om de digitale bestanden te beveiligen.

Artikel: Terren Chong De ontwikkelingen binnen de juridische technologie – AJV nieuwsbrief no.1 2020-2021

Bio Summary 

Terren is the Managing Director and Founder of NxtTech; Caribbean’s first consulting firm of hand-picked independent consultants. He leads a group of truly outstanding and experienced professionals offering expert business improvement, technology consulting, and technology risk services infused by technological innovation. 

He was previously the Digital & Technology practice leader at EY Advisory Dutch Caribbean with over 16 years of consulting and audit experience. He has worked across industries by helping organizations drive process efficiencies and better support and deliver transformational business change through automation and digitalization. 

Terren recently obtained the ‘Strategy in the Age of Digital Disruption’ executive certificate from INSEAD business school and holds a postgraduate degree in IT-Auditing from the VU University (Amsterdam, Netherlands) and has a bachelor’s degree in Information and Communication Technology from The Hague University. 

Terren is also a ‘Register EDP-Auditor’ (RE) and currently a guest lecturer in IT and Cloud for the International Post-Master Accountancy program from the Tilburg University. 


Taskforce Human Trafficking Prevention Curaçao launches awareness campaign

Article by Curacao Chronicles

WILLEMSTAD – Human Trafficking Task Force Curaçao is launching today, on July 30, 2021, the date designated by the United Nations as the World Day Against Trafficking in Human Beings, the website: as part of an awareness campaign.

The website, as part of this campaign, aims to provide more information to the public about human trafficking/smuggling. It also aims to make people who have become victims of human trafficking aware of steps they can take. The Task Force has received a subsidy of € 40 thousand from the Dutch Ministry of Security and Justice for this project. This amount has been deposited into the account of the Crime Prevention Fund.

By raising awareness of the problem of human trafficking, citizens are encouraged to actively report human trafficking practices, or to report this to the police.

Human trafficking includes the recruitment, transportation or reception and housing of people using any form of coercion for the purpose of exploitation. Victims are often in a vulnerable position. They are blackmailed, threatened, mistreated, or misled.

Human trafficking means that people are exploited or put to work under inhumane conditions. It is a serious violation of human rights and a serious crime.

Human trafficking and smuggling have been considered a priority by the Public Prosecution Service for some time now. This form of crime is closely related to the influx of undocumented persons on Curaçao and requires a multidisciplinary approach. As an autonomous country within the Kingdom, Curaçao is bound to comply with agreements that are laid down in treaties that relate to, among other things, human rights. The annual publication of a report on the steps taken in the fight against human trafficking is part of this. This report is assessed by the US Department of State and then they issue a TIP report on the functioning of the country of Curacao. The countries are assessed based on established criteria.

Until 2018, Curaçao was rated at Tier 2. Tier 2 includes countries that do not fully meet the minimum standards but are making significant efforts to meet them.

Since 2019, Curaçao has been placed on the Tier 2 watch list. This means that the country has made a significant effort but has not provided evidence of the increasing efforts to combat human trafficking in the previous year. This is possible through an increase in criminal investigations, prosecutions and convictions conducted locally, an increase in assistance provided to victims and a reduction of complicity in human trafficking by government officials. It also happens when the estimated number of victims has increased or increases significantly, and the country does not take concrete proportional measures.

A place on the Tier 2 “Watch List” means that Curaçao has a bad reputation in the fight against human trafficking.

To get out of this bad position, the Human Trafficking Task Force has put forward various policy proposals over the past three years, which have been endorsed by the Council of Ministers.

In the past five years, a total of 31 complaints and/or reports of being a victim of human trafficking have been filed. Of these, there were 22 convictions.

5 Tips from a Suddenly Unemployed Compliance Professional

Article by Gwendolyn L. Hassan

Finding herself on the wrong end of the proverbial pink slip, compliance pro Gwen Hassan struggled to determine exactly what was next for her. Here, she shares her experience embarking on the next chapter of her career and offers a few guideposts for fellow job seekers.

Like many others in this pandemic-disrupted world, I find myself unexpectedly unemployed. My most recent position was unceremoniously eliminated via a Microsoft Teams call as part of a larger corporate restructuring with almost no notice:

“I’m sorry to inform you: Your position has been eliminated, effective immediately.
Today is your last day.”

I had not been in the office for over a year at that point. I lost not only a job, but also the chance to see again, in person, the friends, colleagues and team members I had there.

My prior eight years were spent building a global compliance program and function for my former employer. I have a giant whiteboard on the wall of my home office that became “command central” when I switched to all-remote work because of the pandemic. It was covered with goals, bright ideas, next steps and to-do items for that program. Once the initial shock of my job loss wore off, I erased everything written on my giant whiteboard. I stared at it and all of its beckoning blank space and thought, “Well, now what?!”

Here are some tips on what to do next should you ever find yourself in a similar position:

1. Take some time to mourn.

Yes, I said mourn. A job loss is just that, a loss. I think this is true for everyone, but it is perhaps especially true for compliance professionals. Our profession by its very nature requires a special focus on developing relationships and on being builders. We build programs and processes and controls, but we also build relationships. We partner with other control functions, with our boards, with our business clients, with our teams and staff and with each other. When you lose a compliance position, it can also feel like you’re losing everything you have built, including all of those relationships. It can be a sudden and jolting loss. So allow yourself the time to process the change. Be gentle with yourself, and give yourself some grace.

2. Get yourself a blank piece of paper (or a blank whiteboard) and embrace the “art of the possible.”

Ask yourself the big questions:

  • What is most important to you?
  • What did you most enjoy about your last position? What did you dislike about it?
  • Are you happiest as an individual contributor, or do you prefer to work as part of a team?
  • Do you want to manage and develop people, or do you prefer to serve as a subject matter expert?
  • Where do you see yourself five years from now? 10?
  • What experiences and knowledge do you need to get you from ‘here’ to ‘there’?
  • What are you willing to sacrifice? What is nonnegotiable for you?
  • Are you willing to return to working in an office, or are you happier working remotely?
  • What is it that you really want out of life and out of your career?

Until you can answer these questions for yourself, you won’t know what to look for! Take the time to embark on this mental journey and then write your own job description. Pour yourself a glass of wine or make yourself a strong cup of coffee (or other beverage of your choice) and write/draw it out. What does your ideal work life look like to you? Where are you? What are you working on? Who are you working with? Create a crystal-clear vision for yourself of exactly what your next step will be.

3. Reach out to your network and tell them you are searching – and what it is, specifically, you are searching for.

I know admitting to people that you are unemployed can feel scary. There has historically been some amount of embarrassment and shame associated with being unemployed – a lingering feeling, even in cases of corporate restructuring, that it might somehow be your fault. I’m here to suggest this is an outdated way to feel.

The reality today is that companies change strategies and priorities all the time. They make business decisions that often, sadly, do not include much concern for the employees impacted by them. The pandemic made this even more prevalent, as companies have been forced to suddenly pivot and adjust to a situation no one expected. Potential employers understand being unemployed happens to even the best and brightest people, so I suggest you swallow your pride and be open and transparent.

This is especially important for the compliance professional. Our profession is based on the very idea of open and transparent communication, of raising your hand when there’s an issue. Well, the issue is now your career, so raise your hand! It’s time to practice what we all preach: reaching out to ask for help when you need it.

You have (hopefully) spent years investing in, building and nurturing your professional network. Now is the time to lean on them for help and advice. Ask them for introductions and recommendations. Ask if you can write an article or record a podcast for them (as I am doing now!). Request that your contacts network on your behalf. Leverage the network you have built for yourself!

4. Develop a back-up plan.

Do you have enough emergency savings and severance to “bridge” you through a long job search? Conventional wisdom says a job search can take a month for every $10,000 in salary you make. What options do you have for bringing in enough income to pay your bills while you search? Are there consulting opportunities available? Is there project work you might take on? Is there a part-time position you might be able to work in for the time being? Having a back-up plan is of vital importance to prevent you from panic-accepting a role that isn’t right for you just to ensure a paycheck. Having a solid back-up plan will empower you to be steadfastly devoted to the vision you created for yourself back in step 2 – and not to settle for anything less.

5. Do something you’ve always wanted to do but never had the time for!

It can be tempting to turn searching for your next role into your new full-time job and allow yourself no days off. I know firsthand the kind of “I have children to support” anxiety that can take over if you let it. I highly recommend, however, taking some time off from your search.

Literally schedule vacation days from your search. Take an afternoon off every week and a few hours to yourself to do things unrelated to your hunt for the perfect next position. We all have lists of things we have always wanted to do, if only we had the time. Well, now is the time to do some of them!

That stack of books on your bedside table you’ve been meaning to read? Now is the time to read them!

Always wanted to watch The Office in its entirety from Episode 1 to Episode 201? Get streaming!

Have you fantasized about learning another language, taking a cooking class or cleaning out that spare room full of boxes you never unpacked when you moved? Seize the day!

Grab lunch with a friend, take a pottery class, learn yoga. Do something you’ve always wanted to do. Find the proverbial silver lining of not working full time and enjoy that flexibility at least a little bit.

I hope you find these tips helpful. They have been crucial for me, as have the many mentors and friends who continue to encourage me as I continue with my own search. Chin-up and eyes on the prize. We’ve got this!