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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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Nothing to Disclose: When the Exit File Becomes the Defence
On 31 July 2026, lawyers for Capital One asked a federal court in Florida to dismiss, this time with prejudice, a claim brought by entities connected to the Trump Organization over the closure of roughly 385 accounts in 2021. The motion targeted a second amended complaint filed after an earlier dismissal and a 90-day discovery period. The bank's answer rested on two propositions. The first was contractual, and the account terms said it plainly: Capital One could close any acc

Elizabeth Travis
6 days ago8 min read


The Same Wrong Answer: What Shared AI Models Do to Financial Crime Controls
On 13 July 2026 four technology companies came under the direct oversight of UK financial regulators for the first time. The Critical Third Parties (Designation) Regulations 2026 named Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Limited and Oracle Corporation UK Limited. The critical services they supply to banks, insurers and market infrastructures now sit under the joint oversight of the Bank of England, the Prudential Regulation A

Elizabeth Travis
Oct 267 min read


The Comfortable Estimate: Europe's Wealth Threshold Rewards the Incurious
On 18 August 2026 the Financial Conduct Authority (FCA) published its wealth management survey report, drawn from around 400 firms in a sector managing close to £1 trillion for more than 5.5 million retail clients. Around one in ten did not verify the source of a client's wealth at all, which is the whole of the obligation left undone. That will be read as a failure of diligence, and it is one. Yet it draws attention away from something the other nine firms in ten certainly d

Elizabeth Travis
Oct 198 min read


Minutes to Break, Months to Notice: Europe's Frontier AI Blind Spot
The European Systemic Risk Board (ESRB) adopted a warning on systemic cyber risks from frontier artificial intelligence (AI) models on 25 June 2026 and published it twelve days later, alongside a letter from the European Central Bank (ECB) to the chief executive of every bank under its direct supervision and an action plan from the European Commission. On 31 July the European Supervisory Authorities (ESAs) closed the sequence with a statement on how financial entities should

Elizabeth Travis
Oct 128 min read


The Price of Deception: What Cheap Fraud Does to Expensive Controls
On 6 July 2026 the Financial Conduct Authority (FCA) published the Mills Review, its assessment of how artificial intelligence will reshape retail financial services by 2030. The commentary that followed went looking for a new crime. The techniques the Review names, deepfakes, synthetic identities and personalised social engineering, are not new offences; they are the methods financial crime teams have countered for years, and what the Review says has changed is that attacks

Elizabeth Travis
Oct 57 min read


One Bank Said No: The Refusal That Stopped Nothing
In December 2018 a company applied for a bank account in Douglas. Amiga Entertainment, incorporated on the Isle of Man two months earlier, wanted to bank with Cayman National Bank. The bank asked where the money behind it came from and was told that its ultimate owner had started out with a $2 million loan from an uncle. In October 2019 a compliance officer asked for the uncle's name and the origin of his funds; nobody replied, and the application failed. Judged as an onboard

Elizabeth Travis
Sep 287 min read


Alerts Are Not Evidence: AMLA Redraws the Monitoring Obligation
On 3 June 2026 the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) opened a consultation on how firms should watch a customer relationship once it has begun. It reads, at first, like housekeeping: guidance issued under Article 26(5) of the Anti-Money Laundering Regulation (AMLR), horizontal in scope, technologically neutral, insistently proportionate. More than 1,200 people joined the public hearing on 2 July, which is not the audience an

Elizabeth Travis
Sep 217 min read


From Operator to Observer: Where AI Accountability Goes to Hide
The Senior Managers Regime (SMR) has spent the best part of a decade making accountability personal. Named individuals. Defined responsibilities. Reasonable steps. People, not just firms, answerable when things go wrong. Yet the Mills Review, published by the Financial Conduct Authority (FCA) in July 2026, raises a quietly unsettling question about that achievement: as firms hand more of the work to artificial intelligence, and the human role drifts from doing to overseeing,

Elizabeth Travis
Sep 146 min read


Transparency for Borrowers: The Register the United States Chose to Delete
The International Monetary Fund (IMF) completed a guidance note on 25 June 2026, released the following month, instructing its staff on how to build financial crime into surveillance, financial sector assessments and lending decisions. Seven weeks later, on 11 August, the Financial Crimes Enforcement Network (FinCEN) published a final rule removing the obligation on US companies to report who owns them. Most of what had already been reported will be erased. The two documents

Elizabeth Travis
Sep 78 min read


Sanctioned Until Convenient: What a 135-Day Designation Tells Compliance
On 12 December 2025 a sitting justice of Brazil's Supreme Federal Court came off the Specially Designated Nationals list in a routine data release, with no press notice of the kind that had announced his designation. On 30 July 2025 the Office of Foreign Assets Control (OFAC) had designated Alexandre de Moraes under the Global Magnitsky programme, twelve days after the State Department revoked his US visa. Treasury Secretary Scott Bessent said he had run a campaign of censors

Elizabeth Travis
Aug 317 min read


The Payment Messages Your Filter Never Reads
Count What Reached The Filter Most screening management information can tell you how many alerts were raised last month. That number describes what the filter did with the messages it received. It is the far end of the process. Ask a different set of questions about what happens at the beginning and things can get a little less clear. How many payment messages did the bank process that month? How many were in-scope for payment screening (probably not screening domestic but I

Andrew Travis
Aug 264 min read


Measuring the Mirror: What FinCEN's Human Smuggling Filings Actually Record
On 13 August 2026 the Financial Crimes Enforcement Network (FinCEN) published a Financial Trend Analysis on human smuggling. It examines 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025, carrying more than $4.9 billion in suspicious activity, and its headline finding is a collapse. Filings peaked at 29,266 in 2024 before falling to 11,018 in 2025, a decline of 62 per cent, which the report sets beside US Customs and Border Protection figures showing crossings

Elizabeth Travis
Aug 248 min read
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