Financial Crime Matters

Kieran talks with Daniel Thelesklaf, Project Director for Finance Against Slavery and Trafficking (FAST) at the United Nations University Centre for Policy Research about the effort to protect refugees fleeing Russia’s invasion of Ukraine from human trafficking. While many governments, organizations and individuals are offering support for refugees that includes information, food, shelter and job placements, “there are traffickers waiting at the borders” with job and other offers that Daniel says are, of course, too good to be true. Financial institutions have a vital role and a responsibility, he adds, in helping those dispossessed by the war obtain banking services if they are to be less susceptible to traffickers and successfully fit into communities where they are resettled.

Kieran talks with Ilze Znotina about the challenges Latvia has faced over the past four years she has been head of the Financial Intelligence Unit, including enforcing sanctions against Russia following its invasion of Ukraine. “Baltic states have suffered… a very similar situation that Ukraine is suffering right now, [but] thankfully not in recent years,” Ilze says, adding that the region is for that reason united in trying to make the sanctions work. “[Ukraine] fights for themselves and all of us in the Baltic states,” she says. Ilze, who became head of the FIU in the wake of the collapse of the country’s second largest bank and under the looming threat the Financial Action Task Force would place the country on its so-called “grey list,” also details how Latvia has moved from those darker days to put in place vigorous anti-financial crime controls.

Kieran talks with Jessica Davis, a veteran of more than 20 years in defense and intelligence roles in government and the private sector in Canada. They discuss the occupation of Canada’s capitol for three weeks last winter by the so-called “Freedom Convoy,” efforts to support the group via crowdfunding, cryptocurrency, and cash as well as the Canadian government’s successful seizure or freezing of much of that funding. Jessica, president of Insight Threat Intelligence and author of “Illicit Money: Financing Terrorism in the Twenty-First Century,” tells Kieran that the unprecedented use of Canada’s “Emergencies Act” to clear the Convoy encampment and seize its funding should kickoff a nationwide debate about financial support for extremist groups. “While there may not have been mass shootings or big riots, there were some very significant impacts that for Canada, and for Ottawa in particular, are really outside the realm of what we consider to be acceptable protests,” Jessica says, reflecting on the thousands of unemployed and million in damage resulting from the occupation.

Kieran talks with John Sifton, advocacy director, and Patti Gossman, associate Asia director, at Human Rights Watch about the dire humanitarian situation in Afghanistan following the return of the Taliban to power. “One in three families is facing food insecurity” from malnourishment to starvation, says Patti, adding that the crisis is affecting not only the already impoverished, but middle-class and working-class people who are no longer paid for their jobs and have no access to their savings. “Sanctions on Afghanistan are an important part of the economic crisis, but they are not the root cause” as actions by the U.S. Treasury have improved the flow of funds to private banks, John says. “But that’s not solving any of the larger macroeconomic problems and liquidity problems,” John argues, in calling for an end to the isolation of the Afghan central bank from the international banking system.

Kieran talks with Olivia Swaak-Goldman, executive director of the Wildlife Justice Commission, about the Hague-based organization’s efforts to stop the illegal wildlife trade and other forms of environmental exploitation, currently the fourth largest source of funds for transnational criminal organizations. Olivia discusses how WJC targets traffickers in endangered species and those having the greatest negative environmental impact with its team of former law enforcement investigators, intelligence officials and prosecutors. Olivia highlights WJC’s recent success in prosecuting ivory and Pangolin smugglers with help from Nigeria and China as well as the ongoing struggle to take down transnational criminals throughout the world who rely on the aid of corrupt officials and are often also engaged in human and drug trafficking. “Wildlife crimes wouldn’t be there without corruption, without fraud, without money laundering,” Olivia says, adding, “Addressing corruption is absolutely essential to tackling wildlife crime.” ACAMS and the World Wide Fund for Nature (WWF)collaborated with the WJC to develop a free training certificate on investigative strategies to aid law enforcement in the use of financial intelligence and other data related to the illegal wildlife trade. LEARN MORE: https://www.acams.org/en/training/certificates/ending-illegal-wildlife-trade-a-practical-guide-for-law-enforcement

Kieran talks with colleague Dr. Justine Walker, Global Head - Sanctions, Compliance and Risk at ACAMS, about the likely shape of sanctions against Russia should it invade Ukraine. In the wake of ACAM’s Second Annual Sanctions Summit, Justine discusses keynote speaker and White House special advisor Peter Harrell’s promise of severe sanctions against Russia should it attack Ukraine and analyzes the Summit buzz about how the United States, United Kingdom and European Union as well as the financial industry are preparing for possible sanctions. “In thinking of good practice… you do need to map your Russia exposure,” Justine says, adding that financial institutions and companies must ask, “Do you have investments in Russia? Do you have people in Russia? What type of securities exposure do you have? Are you exporting to Russia?” In the event of sanctions, she says, corporations should ask “What may you need to withdraw from and are you able to withdraw from that?”

Kieran talks with Anjana Rajan, chief technology officer for Polaris, about the work the not-for-profit does to fight human trafficking, including having helped more than 30,000 trafficking survivors via its national hotline. In looking ahead, Anjana talks about the need to recreate the Internet to end its use by the powerful to exploit the vulnerable, a reality made only worse by the accelerated digitalization of life in the wake of COVID-19. Anjana says the current debate about Web 3, the next generation of the Internet, offers us all a chance to create a better virtual world or to further the Web’s capacity to be used for exploitation. “As a cryptographer, I largely believe in the potential of Web 3 to help restore economic justice to victims and survivors of human trafficking,” Anjana says, “but as a human trafficking expert, I think Web 3 only offers that possibility, not the guarantee.”

Kieran talks with Dr. Tom Robinson, chief scientist and founder of Elliptic, a blockchain forensics company, about the phenomenal growth of decentralized finance, or DeFi. Offering the promise of a wide array of financial services on an inexpensive and inclusive basis, DeFi also presents a significant fraud and money laundering threat, Tom says. Drawing on Elliptic’s recently released report, “DeFi: Risk, Regulation and the Rise of DeCrime, which he co-wrote, Tom covers the need for legislation and greater regulatory oversight to stem fraud and money laundering as well as ways in which blockchain forensics are being used to track illicit funds on DeFi platforms. “I think it is reasonable to describe this as the ‘Wild West’ in that there are fortunes to be made here and fortunes to be lost and that’s happening every day,” says Tom.

Kieran talks with Casey Michel about his just published book, “American Kleptocracy,” which details how the United States has become a favored destination for laundering money for corrupt politicians and other criminals. Competition among states such as Delaware, Wyoming and Nevada for fees for forming corporations and trusts as well as carveouts from oversight won by special interest groups are to blame, Casey says. Casey, an investigative journalist who has been published widely, including in Foreign Affairs, Foreign Policy, The Atlantic, Washington Post, and The Guardian, talks about how financial intermediaries, including real estate agents and lawyers, have profited from aiding criminals by creating instruments to obscure the ownership of illicit funds. And, while optimistic that new legislation and regulation will curtail some of those practices, Casey says other industries used to launder money lack transparency and oversight, including hedge funds and private investment companies.

Kieran talks with Alex Zerden about his time as Treasury attaché at the United States Embassy in Kabul, the worsening humanitarian crisis in Afghanistan and the renewed terrorism threat related to the Taliban’s return to power. Alex, the principal and founder of Capital Peak Strategies, a financial technology and digital asset advisory firm, talks about how the United States presence in Afghanistan was marked by corruption connected to an inflow of money the Afghan economy was incapable of absorbing. He adds that it was nonetheless “seeing the work and sacrifices made by my Afghan counterparts” that got him through his worst days. “By my own research I have identified 17 terrorist organizations [now] operating in Afghanistan,” says Alex, in reflecting on the ongoing challenge the world faces to not reward the Taliban for “bad behavior” but to ease the humanitarian crisis now threatening Afghans.