Anti-financial crime consulting

Banking

Financial institutions form the hub of global payment flows and are therefore not only vulnerable to financial crime, but also have the necessary insights to identify criminal activities in their transactions. They are therefore subject to far-reaching regulatory obligations that are becoming ever more extensive.

Prevention is continually made more difficult for financial institutions by international interdependencies, complex transaction structures, constantly changing criminal schemes, complex ownership structures and technological progress, which criminals also utilise. The use of new technologies is an important tool in meeting these challenges. Manual processes are no longer able to fulfil today's requirements. The topics of risk analysis, transaction monitoring, screening and KYC are particularly in focus here.

We have more than 20 years of experience in the prevention of financial crime in the banking sector and combine specialist and regulatory knowledge with technical expertise.

Payments

The payment sector is increasingly the focus of regulatory authorities: we are seeing fines in the millions or bans on new customer business and even the withdrawal of relevant licences. Companies in the payment sector often transfer large volumes in a short period of time. However, this is also associated with an increased susceptibility to misuse for various financial crime issues, which is why it is necessary to establish effective security measures - particularly with regard to customers and transactions.

We have many years of experience in advising companies in the payment sector and know the specific challenges associated with anti-financial crime. We are happy to support you in identifying your obligations, determining risks and implementing or optimising adequate security measures.

Asset Wealth Management

The prevention of financial crime is becoming an increasingly relevant topic for asset and wealth managers and independent asset managers. The biggest challenge is to cope with the increasing complexity of regulatory requirements at national, European, and global level. With increasingly international business activities, these challenges continue to grow. One industry-specific challenge is dealing with the digital transformation in order to survive in a highly competitive environment. Innovative technological solutions meet the increasing use of online platforms, digital payment methods and cryptocurrencies, which makes it more difficult to identify financial crime. Key elements for prevention in the AWM area are appropriate risk management, the implementation of due diligence obligations with regard to customers and business partners (know-your-customer/know-your-business-partner) and the establishment of a reporting system.

Insurances

The insurance sector has become increasingly vulnerable to financial crime due to its size, diversity and complexity of product offerings and various distribution channels. The considerable sums of money that flow through insurance premiums and claims payments make the industry attractive to criminals. In order to gain the trust of customers, investors and regulators, and to protect the company's reputation, insurance companies and brokers need to focus intensively on compliance and implementation of anti-financial crime requirements and actively monitor regulatory developments. Stricter controls by supervisory authorities and possible penalties for deficiencies are leading to increasing pressure on insurers to improve their measures for preventing and recognising financial crime.

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Trade, industry & logistics

Companies in the trade, industry and logistics sectors are regularly involved in global flows of goods and complex value chains, which exposes them to an increased risk in connection with financial crime. With regard to money laundering, the Financial Action Task Force ("FATF") is increasingly observing the trend of criminals using the non-financial sector to conceal and launder the proceeds of their activities and, if necessary, to evade sanctions. Companies that operate internationally, carry out transactions with cash, are associated with high assets or trade and transport high-value luxury goods or art are particularly vulnerable. Companies in this sector are also more frequently affected by fraud and corruption. Comprehensive prevention therefore requires a future strengthening of financial crime prevention measures in non-financial sectors.

Public sector

Germany is under international pressure, supranational requirements are increasing and complexity is growing significantly. Criminals are constantly utilising new methods and technologies, for example to launder money and cover their tracks. Sanctions are becoming more complex and include a variety of regulations and restrictions. New business models such as crypto-assets or blockchain also mean that authorities have to deal with new issues in order to stay up to date and adapt their monitoring and control mechanisms accordingly.

Close cooperation with other countries and international organisations is also required to effectively combat financial crime. The exchange of information between German supervisory and law enforcement authorities is also becoming more relevant. In order to protect the economic cycle in Germany, the state and economic operators from financial crime, we support the public sector in efficiently designing the structural and procedural organisation of authorities, adequately implementing international requirements (e.g. risk analyses) and qualifying personnel.

Professional sport

High transfer payments, cross-border cash flows and a lack of transparency make professional sport vulnerable to financial crime. Increasing regulatory requirements (e.g. EU Money Laundering Regulation) and growing public pressure show that football clubs in particular need to take a close look at compliance risks.

Anti-financial crime measures can prevent not only money laundering and sanction offences but also other forms of financial crime. Behaving with integrity leads to the avoidance of fines and reputational damage and can prove to be a strategic advantage over competitors in the long term. We support the sports sector in being a role model for integrity and fair play off the pitch as well.

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Real assets (real estate)

We are observing significant challenges in the real estate sector in the areas of financial crime (FinCrime) and compliance and growing problems with reputational damage. In particular, compliance with the provisions of the German Money Laundering Act (GwG) is of great importance, as real estate is often used for money laundering activities. The identification and verification of customers and the implementation of an effective compliance system are crucial to prevent money laundering and fulfil the legal requirements.

At the same time, the property industry is struggling with scandals, insolvency proceedings, fraud and corruption. As a result, investors attribute a higher risk to the property sector, which makes it less attractive.

FinCrime Readiness & Impact Check

Our Readiness & Impact Check is designed to provide you with an initial overview of how your company is positioned with regard to financial crime. There are both internal and external reasons for this, such as a change of personnel in management functions, findings in the course of audits or controls, identified suspicious cases, regulatory changes or increased requirements in supervisory practice. The results report of our Readiness & Impact Check can also be used as proof to supervisory authorities that a review of the influencing factors and security measures in connection with financial crime has been carried out. In particular, companies that have not yet dealt extensively with financial crime issues and the associated obligations can have their impact analysed for an initial holistic overview as a starting point for further activities.

FinCrime risk analysis

Risk analyses are the basis of all preventive measures. It is essential that risk analyses are individually tailored to the respective business model. The type and scope are determined by the respective risk to which a company is exposed and the respective obligations to which a company is subject. In general, the risk areas of business partners, products/services, countries and sales channels must be taken into account.

In companies from the financial sector, risk analyses are currently developing into an automated, ongoing process. In companies from other sectors, it is important to define an approach that is appropriate to the size of the company and the relevant risk factors.

FinCrime Monitoring & Screening

The monitoring of transactions and business activities to identify patterns related to money laundering, terrorist financing and fraud, as well as the screening of business partners against sanctions and embargo lists, terrorists, PEP lists and negative reporting are key elements in the prevention of financial crime. The monitoring of transactions in the financial sector is becoming increasingly challenging due to rising volumes and high complexity of international payment flows, new payment methods and constantly new financial crime patterns. However, it is also becoming increasingly relevant for companies from other industries to monitor their business activities for certain financial crime patterns. The obligation to screen affects all companies in all sectors and the quality of the screening is heavily dependent on the underlying data quality.

FinCrime Investigations & Remediations 

Companies are increasingly confronted with potential cases of suspicion in connection with financial crime. The number of findings regarding identified procedural deficiencies from internal and external audits is also increasing. This is not least due to increased requirements on the part of the supervisory authorities. It is becoming increasingly necessary for companies to initiate internal investigations, followed by appropriate remediations to close procedural gaps. The number of special audits and officially appointed special representatives ("monitorships") is also increasing.

Our experts support you in investigations and remediations as well as in dealing with special audits and special representatives.

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FinCrime Managed Services

Complex and constantly evolving regulations to combat financial crime represent a major regulatory and financial burden for obliged companies. In particular, time-consuming, repetitive activities in connection with know-your-customer checks, transaction monitoring, screening of business partners and the preparation and submission of external reports present companies with challenges.

We support you in meeting these challenges with new strategies and an adaptable operating model. Find out more about our Anti-Financial Crime Managed Services here.

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FinCrime governance models & processes

A financial crime governance model is an important component of a company's risk management strategy in order to identify, monitor and manage related risks and obligations. Synergies between different topics can be taken into account here without losing sight of the necessary selectivity in each case. Key elements of a robust governance model are a clearly defined risk appetite, regular risk identification, a clear tone-from-the-top strategy and clear roles and responsibilities. In addition, there are transparent reporting, escalation and approval channels, guidelines, processes, controls and training.

We support you in implementing and optimising governance models together with processes and control systems, taking into account relevant regulatory obligations, authority expectations and benchmark insights.

FinCrime education & training

Dealing with regulatory focus topics such as money laundering, terrorist financing, financial sanctions, fraud, corruption and market abuse is the responsibility of management ("tone from the top") and requires sensitisation at all levels of a company. We support you in creating internal awareness-raising measures and training content (e.g. for e-learning or classroom training). We also conduct workshops with customised content and QA sessions with target groups in the client's company.