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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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Countering the Countermeasures: How Sanctioned States Exploit Compliance Architecture
When the United Nations Security Council first imposed comprehensive sanctions against North Korea in 2006, the expectation was straightforward. Financial isolation would constrain a rogue state’s capacity to fund weapons proliferation. Two decades on, the US Treasury, the European Union and the UK have built an extensive sanctions architecture spanning asset freezes, trade restrictions, sectoral prohibitions and secondary designation powers. Yet the very sophistication of th

Elizabeth Travis
Apr 277 min read


Compliance Without Conscience: Why Algorithms Cannot Replace Ethical Judgement
When the Financial Action Task Force (FATF) published its updated Guidance on the Risk-Based Approach in 2023, it acknowledged for the first time the growing role of artificial intelligence (AI) and machine learning in anti-money laundering and counter-terrorist financing (AML/CTF) frameworks. The language was cautiously optimistic: these technologies, the FATF suggested, could strengthen the identification of suspicious activity, reduce false positives and allow compliance t

Elizabeth Travis
Apr 207 min read


AML Fatigue: Has Compliance Lost Sight of Criminal Purpose?
When the Financial Action Task Force (FATF) published its original forty Recommendations in 1990, the objective was unambiguous: to deny criminals the ability to launder the proceeds of drug trafficking through the international financial system. Over the three decades that followed, this mandate expanded to encompass terrorist financing, proliferation finance, corruption, tax evasion and a widening catalogue of predicate offences. Successive rounds of mutual evaluations, new

Elizabeth Travis
Apr 136 min read


Sanctioning Themselves: How the Iran War Broke Western Sanctions Policy
In February 2022, the US, the UK and the European Union imposed the most comprehensive sanctions regime in modern history on the Russian Federation. The ambition was sweeping: sever the financial arteries funding military aggression, freeze the assets of those who enabled it and impose a cost so severe that the war economy could not sustain itself. Hundreds of individuals were designated. Russian banks were cut from SWIFT. Sectoral restrictions targeted energy, technology and

Elizabeth Travis
Apr 68 min read


Who Pays for Compliance? The Unintended Consequences of Extraterritorial AML Law
In June 2000, the Financial Action Task Force (FATF) published its first list of Non-Cooperative Countries or Territories, identifying fifteen jurisdictions deemed deficient in their anti-money laundering (AML) controls. The initiative was presented as a necessary corrective: a mechanism for bringing the global financial system into alignment with a common set of standards. Twenty-six years on, the FATF’s mutual evaluation process has matured into one of the most powerful ins

Elizabeth Travis
Mar 308 min read


The Credibility Gap: How Trump Is Rewriting Financial Crime Enforcement
In November 2023, the United States imposed a record $4.3 billion settlement on Binance. It was the largest penalty ever levied against a cryptocurrency exchange. The message was unambiguous: anti-money laundering (AML) controls were non-negotiable, and financial crime carried consequences. Yet less than two years later, President Trump pardoned the company’s founder, Changpeng Zhao, who had pleaded guilty to enabling money laundering on the world’s largest crypto platform. T

Elizabeth Travis
Mar 236 min read


Rules vs Enforcement: Demystifying the UK’s Financial Crime Architecture
On 26 January 2026, the Home Secretary published a policing reform white paper that proposed the most significant restructuring of UK law enforcement in nearly two centuries. At its centre was the creation of a National Police Service (NPS), a single national force that would absorb the National Crime Agency (NCA), Counter Terrorism Policing and Regional Organised Crime Units into one organisation. The white paper, titled From Local to National: A New Model for Policing, desc

Elizabeth Travis
Mar 168 min read


Low Risk by Decree: Why the Epstein Files Shatter the UK’s PEP Presumption
In January 2024, the UK amended its Money Laundering Regulations to introduce a statutory presumption that domestic politically exposed persons (PEPs) present a lower level of risk than their foreign counterparts. The Financial Conduct Authority (FCA) cemented this position in July 2025 with Finalised Guidance FG 25/3, instructing firms to apply less intrusive measures to UK PEPs unless other risk factors intervene. The message was clear: domestic political exposure, in the U

Elizabeth Travis
Mar 96 min read


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
Feb 239 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
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