Corylated

Polycriminality and pangolins: following wildlife crimes’ tracks in financial services

Trade Secret, enablers of the illicit trade in polar bears

Thu, 27 Nov 2025 09:00:00 +0000

In this episode, founding editors Rachel Wolcott and Lindsey Rogerson sit down with Adam Cruise, a South African investigative journalist whose work exposes realities of wildlife trade and conservation policy. Adam shares insights from the acclaimed documentary Trade Secret, which uncovers how legal wildlife trade often fuels illegal trafficking, with devastating consequences for species like polar bears, lions, and rhinos.

The conversation explores the complex web of international agreements, including CITES (Convention on International Trade in Endangered Species), and the troubling role of euphemistic language such as “sustainable utilization” and “conservation hunting.” Adam reveals how these policies, supported by influential NGOs, blur the lines between protection and exploitation, creating loopholes that organized crime syndicates exploit.

Listeners will also learn about the financial crime dimension—how wildlife trafficking intersects with money laundering and poly-criminal networks—and what red flags compliance professionals should watch for. From shocking scenes in Canadian and Norwegian warehouses to the global demand for exotic pets, this episode challenges assumptions about conservation.

Links

Trade Secret

Adam Cruise

Glass eel trafficking connects €3bn money laundering networks

Global Carbon Budget | GCB 2025

Can carbon credits overcome their chequered past & save the planet?

Thu, 20 Nov 2025 09:00:00 +0000

In this week’s Corylated podcast Lindsey and Rachel discuss carbon markets. They begin with the ongoing UN climate conference (COP30) in Brazil and a recap of the current state of CO2 emissions and rollback on sustainable finance rules underway in the European Union. Next, they discuss the alleged $100 million fraud at Cookstove and how it adds to a chequered history of carbon credits. They then move on to outline the financial crime and fraud vulnerabilities of these instruments, as first set out in a 2013 report by INTERPOL and now being explored by the Royal United Services Institute (RUSI). Lindsey then explains the potential behind carbon market initiatives including Carbon Impact X and Carbonplace before the pair discuss how compliance professionals can help mitigate these financial crime risks.

Links

Southern District of New York | U.S. Attorney Announces Criminal Charges In Multi-Year Fraud Scheme In The Market For Carbon Credits | United States Department of Justice

Scoping Corruption in Voluntary Carbon Markets

editorial@corylated.com

www.compliancecorylated.com

www.corlytics.com

No sense of urgency in UK fraud response

Thu, 13 Nov 2025 09:00:00 +0000

The UK still lacks a new fraud strategy, leaving consumers and businesses exposed to escalating threats. In this episode, Lindsey and Rachel unpack why the lack of government action and explore the blame game between tech giants, financial services and policymakers. Meta faces criticism for enabling fraud through its platforms—but Meta points the finger back at payments providers. Meanwhile, identity fraud is becoming a jigsaw puzzle of stolen data, weak controls, and fragmented accountability. Amid the chaos, Starling Bank stands out as a bright spot with its innovative fraud intelligence tool, proving that thoughtful measures may make a real difference.

Links

Starling Bank scam detector tool prompts questions for Ofcom, Meta

New rules proposed to combat SMS scams in UK

UK fraud and fincrime information sharing deemed ineffective, clubby

Serious abuse of the UK corporate register continues despite reforms

Tech firms must be held to account for role in proliferating fraud, incidents surge 17%

Plans around BritCard in the UK are unclear and may be redundant - Compliance Corylated

Will Britcard be panacea for reducing fraud?

Thu, 06 Nov 2025 06:00:00 +0000

In this episode Lindsey Rogerson, founding editor and Elizabeth Lumley, special correspondent, discuss the newly announced plan for a digital ID – or Britcard -- in the UK. Elizabeth highlights the lack of detail in what the government has announced, and they discuss the politicisation of announcement.

The conversation then turns to the digital IDs that already exit in the UK as well as the merits of the numerous examples of introductions of digital IDs by governments in countries including India, Singapore, Brazil, the United Arab Emirates and Estonia. Elizabeth and Lindsey then discuss the bank-led digital IDs initiatives in Norway and Sweden and how a digital ID could help financially excluded individuals to be accepted for banking services.

Finally, the pair discuss what the advent of digital IDs has meant for the reduction and prevention of financial crime and fraud.

Links

editorial@corylated.com

www.compliancecorylated.com

www.corlytics.com

Sterlingov vs the blockchain analytics industry

Thu, 30 Oct 2025 06:00:00 +0000

In this episode, Rachel Wolcott speaks with Patrick Tan, general counsel at ChainArgos about the controversial use of blockchain analytics in criminal investigations, focusing on the case of Roman Sterlingov, convicted of operating Bitcoin Fog. Patrick discusses the limitations and risks of relying on blockchain tracing heuristics as forensic evidence, the amicus brief ChainArgos filed in Sterlingov’s appeal. Rachel and Patrick also discuss the Bybit hack and Iranian crypto flows and nested exchanges.

Rights to reply

Chainalysis declined to comment on the ChainArgos Amicus Brief.

TRM Labs said it did not see a difference between its analysis and ChainArgos’.

Links

Amicus Brief in Roman Sterlingov’s Appeal, also available via PACER (U.S. federal court document access system)

Chainalysis Blog Post Response: “Chainalysis Data Stands Alone: Independently Proven, Accurate, and Reliable”

North Korean hackers’ crypto expertise allows them to steal and launder in plain sight

Undercover North Korean IT workers may be driving crypto thefts

TRM Labs report on Iranian crypto activity

ChainArgos’ report on Iranian crypto activity

Complaints Commissioner’s report on Firm X

Missing the red flags in UK payments service provider failures

Thu, 23 Oct 2025 09:00:00 +0000

In this week’s Corylated podcast Rachel and Niece discuss yet another failed UK payment service provider and examine the UK Financial Conduct Authority’s recent track record supervising this market segment. As UK PSPs continue to fail, the FCA would like to speed up authorisations. Niece and Rachel wonder about these plans, as well as the lighter touch crypto regimes developing in the US and UK. Also, Niece tells Rachel about “strong views” aired at the recent US Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) crypto roundtable!

Links

FCA statement on Premier FX

FCA payments improvement plan not fully implemented, failed firms’ customers £22.5mn out of pocket

Ziglu’s filings show early regulatory intervention

Fifth payments firm enters special administration under FCA’s watch

US TradFi criticises ‘innovation exemption’ policies

Human trafficking transaction detection needs a bigger financial crime toolkit

Getting curious about human trafficking transaction typologies

Thu, 16 Oct 2025 09:00:00 +0000

In this week’s Corylated podcast Rachel speaks to Neil Giles, president of the TraffikAnalysis Hub at UK charity Stop the Traffik. Neil shares his deep expertise in identifying human trafficking through financial transaction data and using persona-based typologies and survivor-informed intelligence.The conversation explores how financial institutions can detect trafficking patterns, the role of typologies, and why getting curious about this crime can help set someone free.

The episode also covers:

• The growing market for child sexual exploitation and its financial footprint

• Payment service providers and high-risk transactions

• The importance of public-private partnerships (PPP) in fighting trafficking

• Case studies including Operation Fort and the Modern Slavery Intelligence Network

• Why financial institutions should act now without waiting for regulators

Warning: difficult subject matter.

Links

Stop the Traffik

UK watchdog has no plans to prioritise human trafficking

Evolving UK people smuggling policy requires new approach from financial crime teams

Compliance Corylated

Corlytics

Q3 enforcement analysis – MAS steps up as French reject Shein’s cookies

Thu, 09 Oct 2025 09:00:00 +0000

In this episode Rachel Wolcott and Lindsey Rogerson discuss third quarter enforcement data provided by Corlytics.

They begin by reviewing the largest fine of the quarter handed down to fast fashion chain, Shein, by French privacy watchdog Commission nationale de l’informatique et des libertés’ (CNIL). Shein was fined US$175.7 million for multiple breaches of Article 82 of the EU General Data Protection Regulation (GDPR) after an August 2023 investigationproblems with the retailers’ cookies.

Rachel then explains the enforcement actions which lie behind a record quarter of fines from the Monetary Authority of Singapore (MAS), before moving on to discuss why anti-money laundering and financial crime are the common theme behind many of Q3’s enforcement decisions.

Finally, they discuss the messages coming from US and UK regulators on future enforcement actions as well as the prospects of more AML-related enforcements from United Arab Emirates. Are enforcements there token gestures or a sign of things to come?

Links:

Q3 enforcement: Singapore fines and bans for AML failings; Shein’s costly cookies

MAS Takes Regulatory Actions against 9 Financial Institutions for AML-Related Breaches

Cookies placed without consent: SHEIN fined 150 million euros by the CNIL | CNIL

Monzo fined £21 million for fincrime failures, third challenger bank fine inside a year

Weak bank customer due diligence in spotlight again after Barclays fined £42 million

Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and Interactive Brokers LLC | Office of Foreign Assets Control

Transparency International Russia (in Exile): “Gold and Crossbows: How Russian Mercenaries Enable Dirty Business in Africa”

Acting Chairman Pham Announces Successful Completion of Enforcement Sprint

Editorial@corylated.com

The Dark Pattern, a conversation with Guido Palazzo

Thu, 02 Oct 2025 10:45:00 +0000

The Corylated podcast is back with a conversation with Guido Palazzo, professor of business ethics at the University of Lausanne in Switzerland. Guido spoke to Rachel this week about his new book The Dark Pattern.

Join Guido and Rachel for a sobering journey through corporate hell exploring the human toll of some of the worst corporate scandals of recent times. Guido and his co-author Ulrich Hoffrage have identified nine traits of the dark pattern and explain how they manifested at companies from Theranos and Wells Fargo to Uber, Foxconn and FranceTelecom—all scenes of serious corporate malfeasance. Finally, Guido and Rachel discuss how ‘The Bright Pattern’ could help organisations fend off such failings.

Warning: contains mentions of suicides.

Links:

The Dark Pattern: The Hidden Dynamics of Corporate Scandals

Guido on LinkedIn

Corylated on LinkedIn

Main Street banks can have Big City financial crime risks

It’s all about (ML/CFT) controls

Thu, 07 Aug 2025 06:00:00 +0000

In this episode Rachel Wolcott and Lindsey Rogerson discuss how the US is diverging from the Rest of the World when it comes to expectation on financial crime expectation and the checks it requires financial institutions to make.

They begin talking about US Treasury plans to reduce Bank Secrecy Act anti-money laundering obligations for smaller banks. Rachel raises the case of Summit National Bank in Hulett, Wyoming (pop. <400) which had plans to go big in fintech with a Bulgarian crypto company. It did not have ambitious ML/CFT compliance plans, however, and US regulators pulled the plug.

Lindsey and Rachel then switch to discussing the recent fines from the UK Financial Conduct Authority on the so-called challenge banks – Metro, Monzo and Starling bank as well as early action against CB Payments. Most of which can be attributed to prioritising growth in customer number of AML and KYC checks. And Lindsey asks what has happened to an essential annual data publication from the Payments Systems Regulator.

Finally, they discuss the European Banking Authority’s recent opinion on the state of AML control at European institutions and the UK’s nine System Priorities for tackling financial crime.

Links:

Summit National Bank, Hulett, Wyoming

Weak bank customer due diligence in spotlight again after Barclays fined £42 million

Monzo fined £21 million for fincrime failures, third challenger bank fine inside a year - Compliance Corylated

National Crime Authority System Priorities

UK-Nigeria partnership to detect, disrupt and deter fraud - GOV.UK

EBA Opinion and Report on ML TF risks.pdf

Editorial@corylated.com

More senior manager penalties coming, says UK watchdog

SM&CR went from ‘just right’ to ‘too much’ in a decade

Thu, 31 Jul 2025 06:00:00 +0000

In this episode Rachel Wolcott and Lindsey Rogerson discuss the proposed changes to the UK’s landmark Senior Managers & Certification Regime (SM&CR). At its inception it was deemed to be framework proportionate to challenge of holding financial services senior managers accountable, but 10 years on the UK government and regulators view some aspects to be a burden. Rachel and Lindsey look back at the post-Global Financial Crisis landscape that brought SM&CR into being, the lack of enforcement action around the regime as well as some of the proposed changes.

Links

Financial Conduct Authority consultation: https://www.fca.org.uk/publication/consultation/cp25-21.pdf

Prudential Regulation Authority consultation: https://www.bankofengland.co.uk/prudential-regulation/publication/2025/july/review-of-the-senior-managers-and-certification-regime-consultation-paper

HM Treasury consultation: https://www.gov.uk/government/consultations/consultation-reforming-the-senior-managers-certification-regime

Editorial@corylated.com

Exclusive: FCA spent over £300k on 23 finfluencer-led campaigns

Cryptically speaking: Increasing use of common financial terminology is blurring crypto risk lines for consumers

Thu, 24 Jul 2025 06:00:00 +0000

In this episode Niece Prayoonrat discusses her recent reporting with Lindsey Rogerson. They begin with failed crypto firm, Ziglu. Niece explains how she first became aware that something might be amiss at the group, before moving on to discuss the uncertainty over whether investors will get any money they had in its so-called “boost deposit account” back.

Niece then turns to neo-broker Robinhood’s recent product launch on the French Riviera, and why its regulator – the Bank of Lithuania – has some questions over its Open AI and Space X private stock tokens. They discuss why the regulator’s decision on compliance with the Market in Financial Instruments Directive (MiFID ii) will be hotly watched by financial firms who have a host of alternative asset tokens waiting in the wings.

Finally, they discuss Niece’s Freedom of Information request which revealed the Financial Conduct Authority had spent £300k on influence-led campaigns. They highlight risks to the regulator from the discovery that all off influencer paid by the FCA also earn referral commissions from neo-brokers. And discuss how regulators need to be much clearer with the public on if, and how, money in crypto “deposits” and “funds” is protected.

Links:

Niece’s articles

Ex-Starling founder’s Ziglu enters special administration

Defunct Ziglu’s finances in doubt last year; directors linked to failed investment firm

FCA: firms should tell us before ‘things go wrong’

Ziglu’s collapse: UK crypto ‘small fry’ struggle to succeed

Regulator seeking clarification on Robinhood's EU stock token launch - Compliance Corylated

FCA creates dedicated ‘neo-broker’ supervision team

Library of Congress archive of New York Stock Exchange investment ad

https://www.youtube.com/watch?v=OQrs6Oa8qtE

Unpacking the Korfuzi judgment and the rise of OCGs involvement in insider dealing

Thu, 17 Jul 2025 06:00:00 +0000

In this episode Rachel Wolcott and Lindsey Rogerson discuss the jailing of siblings Redinel and Oerta Korfuzi at Southwark Crown Court in London on July 4. The pair were found sentenced to a combined 11 years after Redinel used his position as an analyst at Janus Henderson to trade on inside information.

They begin by discussing why the Financial Conduct Authority (FCA) might be a celebratory mood after this and other recent successful insider dealing prosecutions, before considering the details of the judgment and the lessons therein for financial services professionals.

The conversation then moves on to ponder the presence of Sottish and Northen Irish bank notes in two recent FCA criminal cases.

Finally, they discuss recent warnings from UK and French authorities about organised criminal gangs increasingly recruiting junior bank staff for their access to insider information. And crucially what systems and controls these institutions need to have in place to detect and notify regulators when they suspect insider dealing.

Links:

Rachel’s article on the Korfuzi case FCA hails Korfuzi siblings’ long insider dealing sentences

FCA Match Watch 77 – Trading by OCGs Market Watch 77 | FCA

FCA Match Watch 73 – Market conduct and suspicious trading Market Watch 73 | FCA

AMF and French Anti-Corruption Agency (AFA) call for vigilance on OCGs The AMF and the AFA call for vigilance on the risk of private corruption by criminal networks of natural persons with access to inside information | AMF

Finnish Financial Services Authority June Newsletter on suspicious transaction and order reports (STORs) markkinat-tiedote-2_2025_en.pdf

Responses to the European Securities and Markets Authority (ESMA) paper on insider lists Consultation on the Draft implementing technical standards on the extension of the use of the alleviated format of insider lists

Non-financial misconduct

Thu, 10 Jul 2025 06:00:00 +0000

In this episode, Rachel Wolcott and Lindsey Rogerson discuss the UK Financial Conduct Authority’s proposals to apply non-financial misconduct rules to an additional 37,000 regulated firms and lessons from the recent Upper Tribunal decision in the Jes Staley case.

They begin by recapping the findings from the FCA’s survey of non-financial misconduct which was published last year as way of highlighting why the rule changes to the Code of Conduct (COCON) and Fit and Proper assessments is needed.

They discuss why compliance and legal professional think guidance will help firms decide what “serious” bullying and harassment look like and most importantly how to deal with the individuals perpetrating such incidents. They also talk reasonable steps for managers who witness -- or are made aware that a member of their team is suspected of – non-financial misconduct.

The conversation then moves onto consider the implications for financial firms’ senior executives and boards of the recent Upper Tribunal decision against Jes Staley, former CEO of Barclays.

Links:

July 2021 FCA/PRA joint discussion paper: Diversity and inclusion in the financial sector – working together to drive change https://www.fca.org.uk/publication/discussion/dp21-2.pdf

September 2023 FCA consultation paper: Diversity and inclusion in the financial sector – working together to drive change https://www.fca.org.uk/publication/consultation/cp23-20.pdf

March 2024 Treasury Committee Sexism in the City report expresses concern over D&I plans https://committees.parliament.uk/publications/43731/documents/217019/default/

October 2024 FCA survey of non-financial misconduct https://www.fca.org.uk/data/culture-non-financial-misconduct-survey-findings

March 2025 FCA abandons D&I plans https://www.fca.org.uk/news/statements/update-fca-enforcement-transparency-proposals

July 2025 Non-financial misconduct CP published CP25/18: Tackling non-financial misconduct in financial services

Jes Staley and Jeffrey Epstein: Evidence That Doomed Ex-Barclays CEO’s Career (paywall)

Upper Tribunal Decision in Staley case: https://assets.publishing.service.gov.uk/media/685d21fec2633bd820a92a52/Staley_v_FCA_decision_for_release.pdf

The NepoPep: Exploring deep connections between Russian elites

Thu, 03 Jul 2025 06:00:00 +0000

This week we’re bringing an episode featuring Ilia Shumanov, board member at Transparency International Russia in Exile and the co-founder of Arctida, a non-profit focused on challenges facing the Russian arctic. Ilia speaks with Rachel Wolcott, Compliance Corylated’s founding editor about their recent collaboration investigating the son of a Russian Duma deputy and alleged gangster who grew up outside Russia in the US and UK private schools.

Boris Borisovich Ivanyuzhenkov is another wealthy, young Russian with elite connections. Despite his father Boris Viktorovich Ivanyuzhenkov being a high-ranking figure in the legendary Podolsk OCG, young Boris has traveled the world playing tennis and is the director of several property businesses in the US and Europe. He also happens to be best friends with Mikhail Fedotov, son of energy tycoon Viktor Fedotov.

Ilia and Rachel unpack the case and talk about what it says about the challenges for financial crime investigators and journalists!

Links

The NepoPEP: Alleged Russian gangster’s son’s US property company

The NepoPep: Sons of Duma deputy and UK Conservative party donor run German property businesses

Contact

Transparency International Russia

Golden Youth: How a wealthy Gen-Z Russian came to run a cash-to-crypto money laundering scheme from his Kensington flat

Thu, 26 Jun 2025 06:00:00 +0000

This week we’re bringing an episode featuring Ilia Shumanov, board member at Transparency International Russia in Exile and the co-founder of Arctida, a non-profit focused on challenges facing the Russian arctic. Ilia speaks with Rachel Wolcott, Compliance Corylated’s founding editor about the ‘Golden Youth’ series of articles examining one of the actors involved in multi-billion-pound crypto laundering scheme.

Ilia and Rachel recently collaborated on an investigation into the Semen Kuksov case. Kuksov, a young wealthy Russian, was jailed in 2024 in the UK after pleaded guilty to laundering £12 million through his cash-to-crypto operation. Ilia and Rachel unpack the case and talk about what it says about Russian sanctions evasion and money laundering methods today.

Links

First article: Golden Youth, the new face of Russian money laundering and sanctions evasion

Second article: The privileged, privately educated Russian who ran a cash-to-crypto MLAAS for other wealthy Russians and drug traffickers

Third article: Wealthy Gen Z Russian laundered money in luxury properties, claimed ADHD caused offending

Metropolitan police: Money laundering gang who exploited Russia-Ukraine war jailed (press release)

Crown Prosecution service: Men jailed for laundering more than £12m of criminal cash (press release)

Contact: editorial@corylated.com

Hard Bargain: Working in a regulated sector brings responsibilities

Thu, 19 Jun 2025 06:00:00 +0000

In this episode, Lindsey and Rachel cover the sentencing of UK art dealer for failing to report suspicion of terrorist financing when dealing with a sanctioned individual. Oghenochuko Ojiri, who was given two and a half years in prison, subscribed to an art market due diligence service, but did not heed its findings.  Mrs Justice Cheema-Grubb told Ojiri during sentencing: “These offences are so severe that only a custodial sentence can be justified. Working in a regulated sector brings responsibilities, but you closed your eyes to what you knew.”

Listen in for further insights from the sentencing.

Links:

Jailed UK art dealer ignored due diligence platformʼs alert on Hezbollah financier

Full sentencing remarks on Sky News Courts

Compliance Corylated video: Follow the handbags, new reporting rules for high value dealers

UK Financial Intelligence Unit’s SARs report 2023/24

Money laundering risks in UK higher education report

editorial@compliancecorylated.com

Meet the UK FCA’s new enforcement approach, same as the old one

Thu, 12 Jun 2025 06:00:00 +0000

In this episode Lindsey Rogerson and Rachel Wolcott discuss the UK Financial Conduct Authority’s updated version of its Enforcement Guide. They begin by recapping on the intentions behind proposals to change the “exceptional circumstance” test for disclosing if/when a financial services firm was under investigation.

They discuss the entirely foreseeable backlash and justifiable industry concern about naming firms when time for FCA to complete investigations was running at an average of 42 months.

The conversation then moves onto consider where the consultation landed on transparency and what if anything has really changed.

Rachel also shares some insight on the cost of prosecuting small scale insider dealing cases on the back of a response she received to a request under the Freedom of Information Act 2000.

And Lindsey considers whether a House of Lords amendment to the UK Employees Rights might succeed in where PS25/5 failed in encouraging whistleblowers to come forward.

Links:

FCA spent over £300k on insider dealing duo who made £43k

Over 50% of FCA investigations are public

FCA policy statement 25/5: Our enforcement guide and greater transparency of enforcement investigations

House of Lords Financial Services Regulation Committee report: Naming and Shaming: How not to regulate

Recent FCA apologies to Collateral investors, FundingSecure customers, and Basset & Gold minibond investors for slowness in handling complaints about how these firms were authorised and supervised.

Vulnerable customers, digital inclusion: An interview with Howard Taylor, a director at PwC’s risk and compliance practice

Thu, 05 Jun 2025 06:00:00 +0000

UK financial services firms are still falling short when it comes to their vulnerable customers. The Financial Conduct Authority (FCA) explored the issue in its March review, highlighting that the financial services industry is still not doing enough. To unpack the challenge, Niece Prayoonrat, a reporter at Corylated, speaks to Howard Taylor, a director at PwC’s Risk and Compliance Transformation Consulting practice.

Howard participated in the FCA’s panel launching its most recent work on vulnerability and has advocated for a needs-led and customer-focused approach to vulnerable customers. He also offers valuable insights as a wheelchair user.

In this episode, Niece and Howard discuss how organisations and regulators can better serve those who are sometimes left behind. Howard addresses how product and business teams can design products with vulnerable customers in mind, whether a one-size-fits-all approach might actually be harmful, and the overarching vision from current government workstreams.

Links:

Banks fail vulnerable customers; most UK adults reluctant to disclose status

UK elderly fraud victims lose £4,000 per scam, research says

Smart data central to next evolution in banking services

Delivering good outcomes for customers in vulnerable circumstances – good practice and areas for improvement (UK Financial Conduct Authority)

UK could revoke trade and aid in fight against online fraud - Compliance Corylated

compliancecorylated.com

Fraud, between caveat emptor and accountability

Thu, 24 Apr 2025 06:00:00 +0000

In this episode Lindsey Rogerson and Rachel Wolcott begin by discussing why the UK is such a hotbed for fraud and go onto consider the recent drop in authorised push payment (APP) fraud in the UK following the introduction of mandatory reimbursement in October 2024.

The conversation then moves onto the European Payments Services Directive (PSD3) and how it is being updated in an effort to clampdown on the use of virtual IBANs by fraudsters. The lack of user-friendliness of fraud warning lists issued by European and global regulators is then discussed alongside the Financial Conduct Authority's Register.

Rachel and Lindsey highlight instances where the Register has been part of the problem in amplifying the “halo” effect of an FCA authorisation before wrapping up the conversation with a look at how fraud is increasingly perpetrated by international criminal gangs and what the UK’s hotly anticipated UK Fraud Strategy might include.

We’re taking a break and will be back in June with more Corylated. In the meantime, please like, subscribe and leave a 5-star review! Thanks for listening!

Links:

Payment Systems Regulator 2024 APP reimbursement data: APP fraud performance data | Payment Systems Regulator

BBC Panorama episode on Blackmore Bond: https://www.bbc.co.uk/programmes/m001b7jh

UK elderly fraud victims lose £4,000 per scam, research says - Compliance Corylated

UK lost $33.2bn to frauds and scams in 2024 - most in EU

Zelle mentions on Facebook ads ‘correlatedʼ to scams, Meta says   - Compliance Corylated

PSR shares early findings from APP fraud repay scheme 

Disharmony and trade war convergence

Thu, 17 Apr 2025 06:00:00 +0000

In this episode Rachel Wolcott and Lindsey Rogerson discuss the state of play with various sanctions regimes. Following Russia’s invasion of Ukraine in 2022, the United States, European Union, United Kingdom and others imposed sanctions and Russian sanctions are still the big story as the war passed its third anniversary in February.

The return of Donald Trump to the White House caused initial uncertainty, but this month saw the US renew its Russian sanctions package. The discussion looks at how the US, UK and EU have evolved their Russian sanctions, including a close look at two cases in the UK –involving respectively Dmitriii Ovsiannikov and Mikhail Fridman – to gauge how sanctions enforcement is working.

The conversation then moves on to consider how sanctions are increasingly being intermingled with tariffs and other trade barriers, examining both the US action against Canada and Mexico over fentanyl trafficking and China’s recent update to its anti-foreign sanctions law. And covers where compliance teams can turn for guidance when navigating the sanctions quagmire.

Please take a minute to rate this podcast! Your support is appreciated.

Links:

Firms failing to grasp domestic payments’ sanctions risk: https://www.compliancecorylated.com/news/firms-failing-to-grasp-domestic-payments-sanctions-risk/

Sanctions complexity, tough US trade policy boosts risk for fund managers

https://www.compliancecorylated.com/news/sanctions-complexity-us-trade-policy-risk-fund-managers/

Evolving UK people smuggling policy requires new approach from financial crime teams

https://www.compliancecorylated.com/news/evolving-uk-people-smuggling-policy-requires-new-approach-from-financial-crime-teams/

NCA press release on Dmitriii Ovsiannikov https://www.nationalcrimeagency.gov.uk/news/nca-secures-first-convictions-for-breach-of-uk-sanctions#:~:text=Dmitrii%20Ovsiannikov%2C%20the%20former%20Russia,breaching%20the%20UK's%20Russia%20sanctions.

OFSI fine of Herbert Smith Freehills https://ofsi.blog.gov.uk/2025/04/04/hsf-moscow-penalty-key-lessons-for-industry/

US renews Russia sanctions https://www.govinfo.gov/content/pkg/FR-2025-04-14/pdf/2025-06399.pdf

US lifts sanctions on Karina Rotenberg https://www.occrp.org/en/news/us-lifts-sanctions-on-wife-of-russian-oligarch-boris-rotenberg

US removes sanctions on Tornado cash https://ofac.treasury.gov/recent-actions/20250402

They get knocked down, can they get up again?

Thu, 10 Apr 2025 06:00:00 +0000

In this episode Rachel Wolcott and Lindsey Rogerson discuss the timely arrival of the European Union’s Digital Operational Resilience Act (DORA) and the requirement for UK financial institutions to identify their critical third party suppliers.

The Crowdstrike event last summer highlighted the risk of third party suppliers. The need for such DORA/UK work was furthered underscored in letters sent to the UK parliament’s Treasury Committee in February by the country’s nine largest banks. The breakdown of the cause of every bank outage in the last two year is illuminating – issues at third party suppliers accounted for 24 out of a total 120 outages.

The discussion then turns to what lessons can be learned by compliance and risk teams and also considers how current geopolitical tensions could make things a whole lot worse.

Links:

FCA Crowdstrike lessons learned

Which? Report on CrowdStrike incident

Trump’s National Security Firings Come as He Weakens U.S. Cyberdefenses - The New York Times

UK Cyber security and resilience Bill update

UK’s largest banks paid customers £6.2 million after IT outages

Risk managers under-rate third-party vendors’ GenAI use - Compliance Corylated

EU must exempt firms from DORA’s ICT definitions - Compliance Corylated

Banks need active social media response to viral ‘free money’ posts

https://committees.parliament.uk/committee/158/treasury-committee/publications/3/correspondence/

https://www.iosco.org/library/pubdocs/pdf/IOSCOPD767.pdf

Do Over – open banking needs a reset

Thu, 03 Apr 2025 06:00:00 +0000

In this episode, Lindsey Rogerson is joined by Elizabeth Lumley to discuss what is happening with open banking and open finance in the UK, EU and elsewhere. The UK used to be a global leader in open banking but with even the chief executive of the Financial Conduct Authority (FCA) saying recently that the country is falling behind the likes of Brazil and India we take a look at what can be done to course correct.

We discuss what went wrong and what is needed, from government, regulators and incumbent banks to get things moving again and what we could learn from India and Brazil in particular.

The discussion then turns to how regulators can better nurture the start-up and be more sympathetic to requests to explain what and how regulation will impact their businesses. And why every start-up needs a good lawyer.

Links

Open banking’s promise has yet to deliver

The Centre for Finance, Innovation and Technology’s blueprint for open finance

HM Treasury list of promises from Financial Conduct Authority

Earth wind and fire – why mitigating climate risk is now a resilience exercise

Thu, 27 Mar 2025 06:00:00 +0000

In this episode, we take a look at the growing economic risk from physical climate change and the increasing intensity of natural catastrophes as a result of a warming planet. In Europe only around one quarter of damage from natural catastrophes have historically been covered by insurance, in Asia the figure is 13%. And in the US state of California home sales are falling through because potential buyers cannot procure mortgages due to the risk of wildfires.

We discuss how the European Insurance and Occupational Pensions Authority (EIOPA) and the European Central Bank (ECB) have been leading the way in calling for greater cooperation from governments and private sector to boost resilience to natural catastrophes.

Insurers have been stepping up and we discuss some of the technologies that firms have been adopting to better assist customers, improve resilience, reduce premiums and improve claims. We also take a look at the UK’s Prudential Regulatory Authority’s rejection of measures which have boosted the uptake of insurance-linked securities in Singapore.

Links

Keynote speech by Petra Hielkema at the EIOPA Sustainable Finance Conference - EIOPA

The Impact of an Extreme Cloud Burst on Edinburgh Castle and How Important were Human Influences | Royal Meteorological Society

Events | Royal Meteorological Society

Flooding Stockbridge, Edinburgh https://www.youtube.com/watch?v=hfq7mXVzJ1E

Social media’s insidious influence on finance

Thu, 20 Mar 2025 06:00:00 +0000

In this episode, we delve into the powerful role social media plays in amplifying and accelerating financial risks. We revisit the 2023 collapse of Silicon Valley Bank, a prime example of a social media fuelled bank run where $40 billion fled in hours after online doubt spread. Experts and regulators, including Janet Yellen, have highlighted how social media can endanger banks through rapid deposit flight.

We also explore how social media amplifies sows distrust in regulators, auditors and the justice system. The episode touches on how strategic leaks and rumours surrounding mergers and acquisitions amplified online.

The rise of finfluencers and their impact on investment decisions, particularly for Gen Z, is also examined. Regulatory bodies like the US SEC and UK FCA are actively addressing unauthorised financial promotions by these social media figures. Finally, we discuss the alarming statistic that 80% of financial fraud in the UK originates on social media, underscoring the urgent need for proactive measures and the implications of the UK’s Online Safety Act.

Links:

Compliance Corylated, LinkedIN, Corlytics

https://www.compliancecorylated.com/news/risk-managers-should-adapt-their-toolkits-for-social-media-shocks/

https://www.compliancecorylated.com/news/banks-need-active-social-media-response-to-viral-free-money%ca%bc-posts-misinformation/

https://www.compliancecorylated.com/news/meta%ca%bcs-focus-on-high-severity%ca%bc-violations-will-not-stop-organised-crime/

https://www.compliancecorylated.com/news/children-targeted-by-social-media-recruitment-ads-for-money-mules-financial-exploitation-linked-to-other-harms/

Wall Street Journal Report on Silicon Valley Bank: https://www.youtube.com/watch?v=QACGoKb48_0

US FDIC report on the Silicon Valley Bank Twitter bank run: https://www.fdic.gov/analysis/cfr/bank-research-conference/annual-22nd/presentations/cookson-presentation.pdf

Cambridge Disinformation Summit 2025: https://www.jbs.cam.ac.uk/events/cambridge-disinformation-summit-2025/4

Jagolinzer's keynote speech on systemic risks of information pollution: https://www.linkedin.com/pulse/keynote-speech-systemic-risks-information-pollution-alan-jagolinzer-lqole/?trackingId=P0p87Z1DTIW6EsgTFnfr2w%3D%3D5

FCA Primary Market Bulletin 54: https://www.fca.org.uk/publications/newsletters/primary-market-bulletin-5411

CFA Institute report on finfluencer appeal: https://rpc.cfainstitute.org/research/reports/2024/finfluencer-appeal12

YouTube targeted by deep fake: https://www.youtube.com/watch?v=P5N087Hdsc0

Spyware on phones:

https://www.youtube.com/watch?v=WLbHs_S-Fzc

https://www.theguardian.com/technology/2025/jan/31/whatsapp-israel-spyware

Anti-DEI and airlines: https://www.youtube.com/watch?v=qdJLUH95CHA

The Big DEI Rebrand

Thu, 13 Mar 2025 06:00:00 +0000

In this episode, Lindsey Rogerson and Rachel Wolcott talk about International Women’s Day 30 years on and how diversity, equity and inclusion (DEI) conversations have changed as a younger generation (well, younger than us!) come into the workplace.

This year Lindsey found women at a fintech event in London to be optimistic about work and their place at work. She tells us about trends like silent meetings (sounds delightful!) and what young women have to say about mentorship and maternity leave.

Rachel meets some women in Canary Wharf and talks about the state of DEI in the United States. It’s a hot potato, but listen in to find out how Jamie Dimon, JP Morgan Chase’s chief executive is standing up for DEI programs at his firm.

Links:

EU regulators accelerate DEI

UK take on DEI backlash

State Street loses £28 billion pension mandate

US debanking laws, politics complicate financial crime compliance - Compliance

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Taming the Street: An interview with financial journalist and historian Diana Henriques

Thu, 06 Mar 2025 06:00:00 +0000

Financial services deregulation has become a global theme. At a time when policy makers and regulators are seeking to slim down rulebooks governing financial services, Rachel Wolcott speaks to Diana Henriques, author of Taming the Street: The Old Guard, the New Deal, and FDR’s Fight to Regulate American Capitalism.

Diana’s 2023 book dramatizes the birth of the US Securities and Exchange Commission (SEC) in the aftermath of the 1929 stock market crash. How much has conduct and culture moved on from the Wall Street of the New Deal? What can we learn about the early days of financial regulation as lawmakers and regulators seek to unpick rules? A lot, as it turns out. Diana and Rachel discuss…

About Diana

Diana is a prize-winning journalist and the author of five other books on financial history. Her New York Times bestseller The Wizard of Lies was adapted as a 2017 HBO film starring Robert De Niro as con man Bernie Madoff - with Diana playing herself. She also was featured in the Netflix global hit series “Madoff: The Monster of Wall Street.” She retired in 2012 after nearly 25 years at The New York Times, where she was a finalist for a Pulitzer Prize and won a George Polk Award for her 2004 series on financial rip-offs of military consumers.

Links

www.dianabhenriques.com

Cryptos sound alarm on meme coins, but SEC unlikely to regulate - Compliance

Project 2025’s planned bonfire of the regulators ignites uncertainty - Compliance

editorial@corylated.com

FCA most recent (December 19) update for firms on Motor Finance

Newsletter signup https://www.compliancecorylated.com/this-week-corylated/

UK Motor finance and the FCA's surprise claims surge

Thu, 27 Feb 2025 06:00:00 +0000

In this episode, Lindsey Rogerson unpacks the details of the potential claims facing UK motor finance lenders. Lloyds Banking Group the UK’s biggest motor finance lender just upped its provisioning to almost £1.2 billion. And they are not happy about it. The problem arises from the Financial Conduct Authority (FCA) 2021 ban on discretionary commission arrangements or DCAs. These were hidden commissions that incentivized car salespeople to achieve a higher interest rate in turn for a bigger commission. The issue here was no one declared this DCA feature to customers. Once the ban was in place, complaints and claims flooded in, which banks promptly rejected causing consumers to pivot to the Financial Ombudsman Service, which was quickly overwhelmed.

The banks argue they followed the rules. The FCA says despite the ban only applying in 2021, firms shouldn’t have offered DCAs because they breached the FCA principles and consumer lending rules. It’s not clear cut though. There appears to be a disconnect between case law and regulation that may be addressed in a Supreme Court case coming up next month.

Links

FCA announced investigation into historic sales of motor finance involving discretionary commission arrangements (DCA) and a pause in complaints handling

Recording of the February 2024 FCA webinar on its DCA investigation

FCA March 2019 report on commission in motor finance sales

FCA good and poor outcomes on price and value under the Consumer Duty

Decision in the Barclays judicial review of the Financial Ombudsman Service

FCA application to intervene in Supreme Court

FCA publishes request to intervene in Supreme Court case, defends action over motor finance article

Barclays loses judicial review of motor finance case, ombudsman considering next steps article

The White House executive order on crypto

Newsletter signup: https://www.compliancecorylated.com/this-week-corylated/

Deregulatory drumbeat reaching a crescendo

Thu, 20 Feb 2025 10:00:00 +0000

In this first episode of Corylated, founding editors Rachel Wolcott and Lindsey Rogerson discuss how the global political clamor for deregulation is manifesting on the ground in the United States, Europe and the United Kingdom. They discuss how compliance officers need to dial back the noise and stay focused on what rules their firms need to comply with. And go on to discuss the voices emerging to question if deregulation really will lead to economic growth.

Links:

Financial Conduct Authority application to Supreme Court to intervene in motor finance case

House of Lords Financial Services Regulation Committee inquiry into secondary competitiveness and growth objective

Articles for further reference:

FINRAʼs outlook sees tech threat, tech promise - Compliance Corylated

US debanking laws, politics complicate financial crime compliance –