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Our latest thinking on financial crime compliance, regulatory change, technology, and the forces reshaping global risk management.
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From AML to Accountability: Redefining the Modern MLRO
For two decades, the compliance officer has occupied a paradoxical space within financial institutions: indispensable yet often isolated, empowered by regulation but constrained by corporate politics. The role was conceived in the aftermath of global scandals that exposed the fragility of internal oversight, from money-laundering networks that thrived on professional complacency to governance structures that prised revenue over responsibility. The compliance function became t
Elizabeth Travis
4 days ago9 min read


Beyond the Bribe: How Corruption, Money Laundering & State Capture Intersect
For decades, anti-bribery, anti-money laundering, and sanctions compliance have been treated as distinct disciplines. Each has its own regulators, specialists, and compliance programmes, all designed to address specific manifestations of financial crime. Yet in practice, these systems respond to the same underlying pathology: the misuse of power and opacity to extract value from the state. As the Financial Action Task Force (FATF) sharpens its focus on beneficial ownership an
Elizabeth Travis
Feb 166 min read


Integrity by Design: Embedding Ethics into RegTech Architecture
RegTech was born out of necessity, not ideology. After the 2008 financial crisis and a decade of compliance expansion, institutions reached a saturation point. Technology promised relief — a way to automate the repetitive, the reportable, the measurable. But as systems grew faster, the ethics grew quieter. Today, financial institutions are realising that automation without integrity is not progress. It is drift. The question that defines this moment in regulatory technology i
Elizabeth Travis
Feb 105 min read


The Currency of Trust: Why Beneficial Ownership Still Fails the Transparency Test
When the UK launched the world’s first public beneficial ownership register in 2016, it was hailed as a breakthrough for financial transparency. The Persons of Significant Control (PSC) register positioned the UK as a reformer willing to pierce the corporate veil. The logic was compelling: sunlight would disinfect the system, deterring corrupt actors and strengthening public confidence in the legitimacy of corporate Britain. Yet almost a decade later, the system continues to
Elizabeth Travis
Feb 36 min read


This Was Never About £160,000: What OFSI’s Bank of Scotland Penalty Really Signals
The Office of Financial Sanctions Implementation's £160,000 monetary penalty against Bank of Scotland plc is not significant because of its size, nor because it followed voluntary disclosure. It matters because it shows, with unusual clarity, how the Office of Financial Sanctions Implementation (OFSI) now evaluates sanctions compliance in practice. The case illustrates a decisive shift in regulatory emphasis. Transliteration risk is treated not as a technical anomaly but as a
Elizabeth Travis
Jan 317 min read


The Culture of Facilitation: Why Bribery Is Still Misunderstood in Global Finance
In the fifteen years since the Bribery Act 2010 entered into force across the UK, corporate-compliance frameworks have adjusted dramatically. Yet despite the zero-tolerance rhetoric and the sophisticated anti-bribery, corruption and facilitation payment programmes now ubiquitous in large firms, the phenomenon of low-value facilitation payments remains surprisingly resilient in global finance. This persistence reveals more than just enforcement gaps: it exposes a deeper cultur
Elizabeth Travis
Jan 276 min read


Beyond the Algorithm: The Ethical Limits of AI in Financial Crime Detection
Artificial intelligence has become the new backbone of financial crime compliance. Institutions that once relied on human analysts now lean heavily on machine learning to detect anomalies, flag high-risk clients, and predict suspicious behaviour before it happens. Yet behind the promise of speed and precision lies a growing ethical dilemma. The same systems that claim to reduce bias and human error can just as easily reproduce them, only faster and with greater opacity. The q
Elizabeth Travis
Jan 204 min read


Is Open Banking a White Elephant? Rethinking Its Role in the UK’s Financial Future
When the UK Fintech Academic Network convened in May 2025, a provocative question echoed across its panels and breakouts: has open banking become a white elephant? Eight months later, that critique still surfaces in boardrooms and fintech forums, but it increasingly collides with evidence that open banking has moved from “initiative” to embedded infrastructure. A project once heralded as a revolution in consumer finance is now being judged for its limited visibility and uneve
Elizabeth Travis
Jan 135 min read


Phi in Canary Wharf: The Limits of Sanctions Enforcement
It has been twelve months since I last wrote about Phi , the 58.5-metre superyacht detained under the UK's Russia sanctions regime. In that time, nothing has changed. She remains where she has been since 2022, moored in the same spot at Canary Wharf, her bright blue hull fading under the weather and her once-impeccable finish showing signs of neglect. Each morning I see her from our apartment window, an unmissable silhouette against the water. What was once a temporary act of
Elizabeth Travis
Jan 65 min read


Can AI Really Discern Truth in Adverse Media Screening?
Financial crime compliance has always been shaped by the information available to us. We trust media reports, legal filings, regulatory notices, and increasingly, online data streams to help identify risk. As adverse media screening evolves from keyword search to machine-led intelligence, many firms have embraced the promise of scale. The claim that artificial intelligence can scan eight million data sources a day feels like an irresistible answer to a complex problem. Yet th
Elizabeth Travis
Dec 22, 20259 min read


Time to Retire the Whistle? Rethinking the Language of Ethical Reporting
The financial services industry has long relied on employees to act as a final line of defence against misconduct. From exposing...
Elizabeth Travis
Dec 19, 20255 min read


From Static Lists to Smart Networks: The Future of PEP Screening Risk
A Politically Exposed Person (PEP) is an individual entrusted with a prominent public function who may present a heightened risk of...
Elizabeth Travis
Dec 12, 20255 min read
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