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MR. BAS A.S. VAN LEEUWEN (LL.M., ESQ) believes that when knowledge travels, opportunities arise. The attorney thinks client-focused, acts fast and speaks frankly in a language that you understand. He makes sense, not nonsense. Expect accessible personality, an open mind and a pragmatic bullet point approach.

White paper – Comprehensive approach to deterring and preventing Procurement Fraud

Employees may be trusted with certain procurement responsibilities which can provide opportunities to commit fraud-related offenders. It’s difficult to identify the risks. A common sense approach is always essential.

In this white paper, learn more about our comprehensive approach to deterring and preventing Procurement Fraud

White paper – Comprehensive approach to deterring and preventing Invoice Redirection fraud (or Mandate Fraud)

Invoice Redirection fraud (or Mandate Fraud) occurs when your company receives a request to change a direct debit, standing order or bank transfer mandate, from someone purporting to be from another organisation to which regular payments are made, for example a business supplier. It generally takes place when a criminal impersonates your company and deceives the customer into making payment of the company’s genuine invoices to a fraudulent third party account instead.

In this white paper, learn more about our comprehensive approach to deterring and preventing Invoice Redirection fraud (or Mandate Fraud).

A comprehensive approach to deterring and preventing Private Automatic Branch Exchange (PABX) Fraud (White Paper)

Private Automatic Branch Exchange (PABX) Fraud has serious consequences for organizations operating in an international business environment. In such an environment, organizations are operating under serious pressure, competition is stiff and margins are tight. This, in conjunction with trying to adapt to unfamiliar legal systems, conventions and specific political circumstances, can make doing business in an international environment very difficult. There is therefore much depending on whether an organization can win a contract, obtain a license or market a product in good time.

In this white paper, learn more about our comprehensive approach to deterring and preventing Private Automatic Branch Exchange (PABX).

White paper – Comprehensive approach to deterring and preventing CEO Fraud

Business Email Compromise (BEC) Fraud (or CEO Fraud) is similar to Invoice Redirection Fraud however in this case junior employees in the finance department of a company receive an email from a fraud perpetrator purporting to be the Chief Executive Officer stating that an important deal or some other urgent matter is pending and that a substantial payment needs to be processed immediately.

In this white paper, learn more about our comprehensive approach to deterring and preventing Business Email Compromise (BEC) Fraud (or CEO Fraud)

White paper – Comprehensive approach to deterring and preventing Computer Software Service Fraud

Fraud perpetrators may cold call you claiming there are problems with your computer and they can help you to solve them. Those fraud perpetrators often use the names of well-known companies such as Microsoft, Apple or IBM. They could even use the name of your broadband provider to sound more legitimate.

In this white paper, learn more about our comprehensive approach to deterring and preventing Computer Software Service Fraud.

White paper – Comprehensive approach to deterring and preventing Telephone Fraud

Telephone fraud involves criminals contacting you by phone (vishing) or by text (Smishing) pretending to be your bank, credit card issuer, utility company or often a computer company. During the conversation they will try and trick you into giving personal, banking or security information. Fraud perpetrators may also convince you to make a money transfer to them or inform you that you have won a prize and need to send money to release it. Their intention is to use this information to commit fraud against you or other parties in your name.

In this white paper, learn more about our comprehensive approach to deterring and preventing Telephone Fraud.

White paper – Comprehensive approach to deterring and preventing Email Fraud

Email fraud (“Phishing”) involves fraud perpetrators making contact by email and can take a number of forms. The email may appear to be from a reputable company however when one clicks on the email or attachment or link within the email, malicious software (malware) is downloaded onto the PC or other device allowing the fraud perpetrator to track online activity and identify personal or financial information for fraudulent purposes. Both individuals and companies can be victims of this type of crime.

In this white paper, learn more about our comprehensive approach to deterring and preventing Email Fraud

COVID-19 Pandemic: The financial crime threat for private and public organizations

Financial Crime Risk Management (FCRM) in private and public organizations has undergone big changes due to paradigm shifts in business dynamics, emerging threats, regulatory climate and technological advancements. However, in the last few months, the world has been experiencing something unprecedented that has made all other changes somewhat secondary: The Coronavirus (COVID-19). This once-in-a-lifetime phenomenon will change the face of Financial Crime Risk Management (FCRM), compliance and sanctions forever. In this article, I will examine the far-reaching impacts of COVID-19 on financial crime and how private and public organizations can address them.

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Managing financial crime risks during COVID-19 Pandemic

§1. Introduction

The COVID-19 Pandemic still continues to grow with increased impact on the Dutch economy triggering business continuity and crisis management responses across organizations of all sectors and sizes. At the same time, the financial services industry faces new unique threats from fraud perpetrators and continued expectations from regulators that Anti-Money Laundering (AML) Investigations and Compliance services must be maintained despite the disruption to business-as-usual.

Praetor Forensic Auditing provides the services required to help private and public organizations identity the nature and extent of financial crime and deliver appropriate remedies: Fraud Risk AssessmentFraud Risk ManagementFraud InvestigationsCompliance AssistanceIntegrity Due DiligenceForensic Business IntelligenceLitigationNegotiationReputation ManagementForensic Technology and Discovery Services and Legal Department Operations.

§2. PRAETOR FORENSIC AUDITING’s Strategic Analysis, Advisory Services and Operational Support

§2.1. Fraud Risk Assessment

Anti-Fraud provides an independent and objective assessment of the organizations existing anti-fraud program, gaps in the existing controls and suggest measures to mitigate the gaps.

Praetor Forensic Auditing assists its clients in setting up a monitoring framework, developing relevant checking procedures and identifying key risk indicators of fraud. It also develops training programs for employees, and helps to create a continuously evolving control environment reflective of the risk landscape.

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§2.2. Fraud Risk Management

To deter the occurrence of fraud, Praetor Forensic Auditing provides clients with expertise to set-up and implement a visible and transparent fraud risk management program that allows to create an anti-fraud environment.

Praetor Forensic Auditing assists private and public organizations with turning critical and complex issues into opportunities for resilience and long-term advantage. This involves identification of modus operandi as to how did the financial crime occur, who was involved, what were the extent of losses, and how can it be prevented from recurring.

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§2.2.1.       Our Anti-Fraud Strategy

The Praetor Forensic Auditing’s anti-fraud strategy has four (4) main components: a) Prevention, b) Detection, c) Response, and d) Deterrence. The various elements of an effective anti-fraud strategy are closely interlinked and each plays a significant role in combating fraud. The combination of effective fraud prevention, detection and response measures will create an effective fraud deterrent.

§2.2.2.       Fraud Prevention

The attitudes within your organization lay the foundation for a high or low fraud risk environment. Where minor unethical practices may be overlooked, larger frauds may also be treated in a similar lenient fashion. In such an environment there may be a risk of total collapse of your organization either through a single catastrophic fraud or through the combined weight of many smaller frauds.

A sound ethical culture and sound internal control systems are essential key components of a fraud prevention strategy.

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§2.2.3.       Fraud Detection

There are a range of financial crime indicators – both warning signs and fraud alerts – which can provide early warning that something is not quite right and increase the likelihood that the fraudster will be discovered.

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§2.2.4.       Fraud Response

Any organization should set out its approach to dealing with fraud in its fraud policy and fraud response plan. Organizations should ensure that this includes provision for learning lessons from fraud incidents and appropriate, prompt follow-up action.

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§2.3. Fraud Investigation

Fraud Investigation helps organizations manage the risk an vulnerabilities that come from global corruption, from high profile and complex financial matters to employee, cash, cybercrime and fraud. 

Praetor Forensic Auditing assists its clients with investigation of alleged fraud or corruption perpetrated against corporate and government entities, including, but not limited to, vendor fraud, payables fraud and embezzlement. It also assists with factual, often privileged, investigation of alleged corporate wrongdoing, including, but not limited to, investigation of alleged financial statement misrepresentations and violations of anti-corruption regulations. Praetor Forensic Auditing’s investigation work includes forensic imaging of computers, data analysis, collection and analysis of data, interviews of individuals and review of documents.

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§2.4. Anti-Corruption

Praetor Forensic Auditing helps its clients understand and respond to anti-bribery and corruption compliance in all its phases, even when the businesses span many jurisdictions and are governed by many regulators. It assists in determining loose controls posing risk of violation of FCPA and Bribery Act, showcasing company’s views on corruption and bribery to regulatory bodies and also provide training to employees regarding FCPA, Bribery Act and related provisions.

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§2.5. Compliance Assistance

Corporate executives and board of directors have increasing demand on evidences of whether their corporate compliance infrastructures, processes and controls are effective, integrated, efficiently risk-aligned and embedded throughout a complex, global organization. Effective and cost-efficient management of legal, regulatory and reputational obligations is a critical element of corporate governance and enterprise risk management.

Praetor Forensic Auditing assists its clients in assessing, improving and monitoring their compliance programs. Praetor Forensic Auditing’s work includes compliance risk assessment, compliance program gap assessment and improvement recommendations, design implementation assistance for compliance process, deployment of governance, risk and compliance, technology, and data analytics and compliance monitoring.

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§2.6. Integrity Due Diligence

Integrity Due Diligence (“IDD”) is the gathering of independent information to gain an understanding of the integrity and corruption risks associated with a third party. It provides companies with a means to both identify these risks and confirm (or otherwise) information provided to them by a third party.

Praetor Forensic Auditing conducts integrity due diligence services for clients across multiple sectors to help mitigate risks from new commercial relationships and to inform their strategic decision-making.

Companies with an international presence (or plans to expand internationally) are placing an increased emphasis on the need to understand the integrity risks posed by the third parties with whom they contract in those countries (including their representatives, agents, distributors and critical members of their supply chain), in particular for compliance purposes in light of new extra-mural anti-corruption legislation introduced in many western jurisdictions.

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§2.7. Forensic Business Intelligence

Forensic Business Intelligence assists in conducting research and collecting information about a target or an entity through searches on public domain information sources on-site visits and interviews. 

Praetor Forensic Auditing provides Forensic Business Intelligence Services to eliminate opportunities for fraud. We advise clients when the need further information about a potential business partner, another party in a hostile takeover, a competitor or a commercial opportunity. Entering into any significant commercial transaction involves risk, but by providing relevant an reliable intelligence we help clients make better decisions.

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§2.8. Litigation Support

Litigation support is all activities, usually within the law firm, that is designed to prepare a lawyer to try a case, including document review, interviewing witnesses, and case preparation. Litigation support activities include the organization of documents, including paper-based document management, but increasingly through technology such as litigation support software and systems. Documents are organized into searchable databases for review and production.

Praetor Forensic Auditing provides litigation support to its clients, often working alongside their external legal teams, to design and implement investigation strategies and obtain admissible evidence. It also work directly with law firms to enhance their resources and enable them to provide more cost-effective solutions to their clients. As well as legal remedies, Praetor Forensic Auditing has a detailed understanding of extra-legal strategies that can achieve the best outcomes for clients, having worked closely with law firms, media consultants and business advisors in many past cases.

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§2.9. Strategy Consulting

Praetor Forensic Auditing works with leadership to build effective compliance solution strategies to see what is around the corner, and to help leaders understand their risks and responsibilities. It doesn’t simply provide strategic advice. It provides the good counsel and program agility needed to meet current and future regulatory obligations. Most importantly, Praetor Forensic Auditing works with executive leadership to formulate sound strategies that can be efficiently operationalized to achieve results.

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§2.10. Risk Advisory

Praetor Forensic Auditing keeps pace with regulatory change, maintain an ongoing dialogue with regulators, and employ best-in-class solutions to create effective compliance programs for its clients. Praetor Forensic Auditing’s comprehensive approach delves deeply into the regulations and its clients’ business processes to identify and quantify each organization’s individual risks, as well as find, prioritize, and help close any gaps.

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§2.11. Independent Review

Enforcement actions and penalties continue to expose systemic failures and areas of noncompliance within a financial institution’s Bank Secrecy Act (BSA) / Anti-Money Laundering (AML) program and Office of Foreign Assets Control (OFAC) program. Additionally, internal audits or investigations may illuminate areas of potential weakness or concern.

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§2.12. Technology Innovation

Praetor Forensic Auditing provides holistic services related to customer due diligence, sanctions screening, and transaction monitoring technology solutions at a variety of financial institutions- from global, industry-leading banks- to small, regionally focused institutions.

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§2.13. Forensic Technology and Discovery Services

Praetor Forensic Auditing leverages proven methodologies, as well as innovative and proprietary technologies, to identify relevant investigative and dispute resolution evidence in a timely and credible manner.

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§2.14. Legal Department Operations

New technologies and processes are transforming in-house legal departments, but staffing models, too, are shifting to create new efficiencies and respond to the need for updated departmental skills and expertise.

Meet the legal department operations (LDO) professionals – a new position in corporate legal departments that is increasingly helping free up attorney time to focus on legal matters instead of operational ones. The recognition that operations, innovation, technology, and procurement should actually be the responsibility of an identifiable individual, rather than part of the portfolio of the general counsel is the biggest emerging trend in legal operations.

The legal department operations (LDO) professional is typically occupied with project management, financial planning, and managing outside counsel. But these legal department operations (LDO) professionals are also responsible for strategy, goal setting, and managing budgets, people, and vendors. Additionally, legal department operations (LDO) professionals play a crucial role in change management, which might explain their recent popularity.

The legal department operations (LDO) professional is often the person to decide what technology changes make sense and to determine how those technologies should be implemented with consideration of financial and operational implications such as budgeting, staffing requirements, outsourcing, and training.

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§3.    Taking action to manage financial crime risks during COVID-19 Pandemic

§3.1. Maintain culture of compliance with virtual teams

§3.1.1. Ask your organization

  • Does my organization have the technological capabilities to handle a large number of employees now working remotely?
  • Are my teams able to conduct their compliance responsibilities (KYC, TM/Sanctions alert review, Investigations) effectively to ensure compliance with regulatory requirements?
  • If company devices are being used from home, are cybersecurity and sensitive information risks being adequately addressed?

§3.1.2. Potential response strategies

  • Consider the impact on compliance, productivity and cybersecurity of using various technology solutions available.
  • Leverage technological solutions to provide virtual training on new fraud and Anti-Money Laundering (AML)typologies, as well as on revised digital processes from the manual, paper-based processes which are no longer feasible.

§3.2. Added workload with short term loan applications

§3.2.1. Ask your organization

  • Does my organization have processes in place to screen short-term loan applications?
  • Does my organization have the capacity to process the volume?
  • Does my organization have the capacity to onboard clients virtually?

§3.2.2. Potential response strategies

  • Consider your resource requirements for the short-term loan application process.
  • Create, document and deploy new technologybased processes for handling these applications.
  • Assess your methods of onboarding to ensure they meet regulatory requirements.

§3.3. New COVID-19 fraud typologies

§3.3.1. Ask your organization

  • Are my employees and customers aware of the new fraud typologies such as COVID-19 themed phishing attempts that can result in theft of personal data to enable account takeover, credit / loan fraud, card not present fraud, payment diversion fraud, among many other deception schemes?

§3.3.2. Potential response strategies

  • Provide ongoing and up-to-date training to ensure awareness among employees of the new fraud typologies and actions to be taken in order to prevent and detect them.
  • Review and/or employ your cyber incident response strategies and if necessary, consider the information security and data privacy impacts.
  • Ensure your fraud and Anti-Money Laundering (AML) teams are wellconnected to ensure timely reporting of suspicious activity to the Dutch Financial Intelligence Unit.

§3.4. Transaction monitoring of changing consumer behaviour

§3.4.1. Ask your organization

  • How is my customer’s behaviour changing given the pandemic? For example, is your organization faced with an increased number of cash withdrawals?
  • Do my Transaction Monitoring (TM) rules account for deviations from the historical customer profile and could the change in consumer behaviour result in increased monitoring alerts? For example, is your organization faced with increased usage of digital channels by customers to undertake their financial affairs?
  • How should Transaction Monitoring (TM) alerts be prioritized based on the disruption to business-as-usual given the regulatory focus on STRs?

§3.4.2. Potential response strategies

  • Leverage data analytic insights to understand the new consumer behaviour and segment high risk profiles for closer monitoring.
  • Re-assess Transaction Monitoring (TM) models to appropriately capture the new risks posed by new COVID-19 related fraud typologies.
  • Consider your resource requirements for the potential of an unexpected surge in monitoring needs.

This publication contains general information. The Serious Fraud Investigation Office (Van Leeuwen Law Firm | Praetor Forensic Auditing) is not, by means of this publication, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. The Serious Fraud Investigation Office (Van Leeuwen Law Firm | Praetor Forensic Auditing) shall not be responsible for any loss sustained by any person who relies on this publication.
Copyright © 2020 The Serious Fraud Investigation Office (Van Leeuwen Law Firm | Praetor Forensic Auditing), All rights reserved.
COVID-19 Pandemic: The financial crime threat for private and public organizations

Financial Crime Risk Management (FCRM) in private and public organizations has undergone big changes due to paradigm shifts in business dynamics, emerging threats, regulatory climate and technological advancements. However, in the last few months, the world has been experiencing something unprecedented that has made all other changes somewhat secondary: The Coronavirus (COVID-19). This once-in-a-lifetime phenomenon will change the face of Financial Crime Risk Management (FCRM), compliance and sanctions forever. In this article, I will examine the far-reaching impacts of COVID-19 on financial crime and how private and public organizations can address them.

Increased cyber (financial) fraud

Money transfers through online wallets and online payments, including e-commerce transactions, were used moderately in the past. However, these have now become one of the only ways to conduct transactions due to social distancing measures. Seizing this opportunity, fraud perpetrators equipped with the latest technology are perpetrating more sophisticated online transaction frauds. Because a large part of the global population is not tech-savvy enough to ward off the (financial crime) risks associated with online transactions, they are becoming victims of social engineering and cyber (financial) frauds.

Proliferation of money mule-induced laundering

COVID-19 is going to trigger many small-value fund transfers from various governmental bodies, non-governmental organizations and other agencies to fund relief work. Therefore, transaction patterns may stray from the norm. Any Transaction Monitoring (TM) system will need some time to get tuned to these patterns, and this time will ironically present a golden opportunity for launderers to route funds through money mules and escape detection. Fear of being laid off and the lure of earning income from home will entice people into becoming money mules. Most of the leading regulators, including the Dutch National Police, have warned private and public organizations to be vigilant about any such situation.

Imposter scams

A pandemic of this magnitude brings panic and anxiety among the masses, which in turn presents an opportunity for imposters to design scams impersonating government agencies, international relief organizations or healthcare service providers. One such scam that is already occurring involves banking institutions’ moratorium on equated monthly installments. Borrowers are being contacted by fraud perpetrators over the phone or by email and being asked to reschedule a loan as a relief measure. This allows fraud perpetrators to extract account details and siphon off funds in no time.

Money laundering camouflaged as COVID-19 relief

While the world adapts to fight The COVID-19 Pandemic, launderers are using this time to transfer illicit funds under minimal or no suspicion. Regulators such as the European Banking Authority (EBA) have already warned banking institutions about emerging criminal activity linked to COVID-19.

As stated by the European Banking Authority (EBA), “As most economies are facing a downturn, financial flows are likely to diminish. However, experience from past (financial) crises suggests that in many cases, illicit finance will continue to flow.” Other major regulators have also released similar COVID-19 guidelines. It is incumbent for cash-starved banking institutions to maintain high levels of rigor while monitoring cash transactions.

COVID-19-related insider trading

The current COVID-19-crisis has impaired the business dynamics that drive economic activities in a normal scenario. Only essential companies are open under strict regulatory control. As a result, governmental policies and decisions carry huge implications on trading prices of stocks and if used scrupulously, can lead to market abuse.

Cybercrime and associated crypto-threats

There are reports of cyber-criminals taking advantage of COVID-19 to scam the vulnerable public. Some examples include the following:

  • Healthcare providers being attacked by ransom-ware such as Bitcoin ransom-ware, which is wreaking havoc on the already stressed hospital information technology (IT) infrastructure and cashing in on the COVID-19 Pandemic.
  • Cyber-attacks on the depleted security systems of organizations due to limited staff presence and unpatched vulnerabilities.
  • Launching fake mobile apps, which claim to be providing information on COVID-19, aimed at stealing personal data or even rendering phones unbootable.

All the above developments have two things in common: fear and chaos caused by The COVID-19 Pandemic. This has provided the perfect platform for launderers and fraud perpetrators to thrive until private and public organizations develop a defense mechanism and adaptations become institutionalized. Private and public organizations must quickly improvise to this changed scenario to avoid further damage.

Managing the impact of COVID-19: A job made for private and public organizations

Having understood the gravity of the problem, private and public organizations must now address (financial) crimes triggered by COVID-19. One silver lining in this grim situation is seeing several innovations develop that were unimaginable just a few weeks ago, such as the production of ventilators by car manufacturers and the conversion of trains, ships and even airplanes into hospitals. Private and public organizations are likely to create their own innovative solutions to stay afloat during these testing times as well. The following are realignments that might be used to mitigate COVID-19-related financial (crime) risks.

Strengthening Suspicious Activity Report (SAR) investigation, factoring in emerging risks and enhancing automation

As most client interactions for banking are now happening through online channels, anti-money laundering (AML) procedures will change. The financial (crime) risk perception of banking institutions should also change accordingly as bad actors will introduce newer forms of suspicious activities into the system. The Dutch Authority for the Financial Markets (AFM) has already advised private and public organizations to remain alert to malicious/fraudulent transactions from exploiting The COVID-19 Pandemic.

Given the above changes and with minimal staff strength at their disposal, banking institutions that have introduced automations in the past will gain from these implementations. Others will need to work hard to introduce cognitive Robotic Process Automation (RPA) based on Suspicious Activity Report (SAR) investigation and reporting solutions to meet this challenge.

Fine-tuning adverse media screening

As part of anti-money laundering (AML) investigations, adverse media screening is performed to ascertain whether the investigated entity is involved in anything negative such as criminal proceedings, penalties and fines, involvement in laundering of funds, and so on. Important aspects of adverse media screening include news categorization, context-sensitive interpretation and automation of screening process. With COVID-19 introducing new sets of (financial) crime typologies, private and public organizations will face increased false positive alerts as well as true positive misses. Therefore, private and public organizations need to review their media screening and introduce necessary changes to stay effective. In short, private and public organizations must redefine screening typologies for drawing insights.

New scenario building for Transaction Monitoring (TM)

Like adverse media screening, Transaction Monitoring (TM) scenarios will also need to be adjusted so newer forms of money laundering are kept in check. Therefore, banking institutions need to review Transaction Monitoring (TM) scenarios and introduce Artificial Intelligence (AI)-based detection wherever possible to take care of any new anomalies or pattern changes automatically.

Stricter insider-trading detection through Artificial Intelligence (AI)-based models

Insider-trading as a result of regulatory policy information being leaked must be addressed. Additional scenarios to consider include timing of policy information dissemination and timing of trading. This will be a tough job as it needs to be accomplished in the interest of market integrity. A more rigorous trader and employee communication surveillance will also help a great deal.

Finding newer acceptable ways to perform Know your Customer (KYC) updates

Know your customer (KYC) updates will have serious challenges as social distancing measures continue. Private and public organizations need to develop a robust mechanism using unconventional channels wherever possible, such as online data collection for collecting customer data.

Enriching fraud scenarios with the latest event information

As newer forms of frauds are gaining prominence, Private and public organizations need to enrich their fraud event repository so COVID-19-induced frauds are not missed. Here again, Artificial Intelligence (AI)-based detection models will be quite handy for making unsupervised adjustments in flawed indicators.

Keeping cyber threats at bay by deploying adequate staff

Cyber-security and data breach prevention are nonnegotiable under all circumstances. These are now even more critical due to the following factors:

  • Stress of digital transaction volumes on IT-infrastructure
  • Current onslaught of cyber-criminals
  • Data access by employees working from remote locations

Any frugality in terms of staffing this function will only attract hefty financial and reputational losses and cause severe business continuity issues. Therefore, IT-support should receive top staffing priority.

Including the above-mentioned set of measures, the broad readiness agenda for C-level risk and compliance heads of private and public organizations is depicted below.

Conclusion

The COVID-19 Pandemic will likely be present for the foreseeable future, so appropriate changes in how companies manage (financial crime) risks must be made. After getting over the initial hiccups of grappling with immediate business continuity challenges, (financial crime) risk and IT teams of private and public organizations are now gearing up for the next challenges: how to plan, introduce and institutionalize the above-mentioned adaptations that will help them currently and in the long term. As there is less time to react, operational resiliency and managing speed of change is of utmost importance. One thing that will help private and public organizations a great deal is introducing Artificial Intelligence (AI)-based capabilities, which have very high levels of adaptability to changes in data and information by learning from newer patterns, anomalies and outliers. Private and public organizations that already have these capabilities stand to gain a lot and will be better equipped to handle this COVID-19-crisis now and in the future.

However, it is not possible to develop these capabilities overnight if not existing in their current ecosystem. Therefore, it will be prudent to develop a two-pronged strategy comprising of strategic and tactical measures. The following are key elements of this strategy:

  • All types of detections might be improved through strategic measures, i.e., either by deploying new Artificial Intelligence (AI)-based models within a reasonable time or fine-tuning existing models. For example, money laundering or fraud detection models might be retrained with additional data in order to maintain their detection effectiveness.
  • Changes in manually performed activities might be handled through remediation in the short term so that compliance objectives are quickly achieved. However, in the long run, they would require measures like Robotic Process Automation (RPA) to save effort and time as well as meet new compliance requirements.

Regardless of the strategy, it is important to stay compliant at all times as regulators are not going to provide any major leeway during this hour of COVID-19 Pandemic.