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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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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


The Tortoise Strategy: Avoiding the AI Shortcut in Financial Crime Compliance
AI-generated fable remix: the tortoise plays it safe, the robot hare bolts ahead, but who is the ultimate winner? Generative AI, once a...

Elizabeth Travis
Dec 5, 20256 min read


Bribery in Broad Daylight: Are Developing Nations Really More Corrupt than the West?
The assumption that bribery and corruption are more prevalent in developing nations has been a longstanding tenet of both media...

Elizabeth Travis
Nov 28, 20254 min read


Inside the Fraud Supply Chain: How Criminal Networks Industrialise Financial Crime
Fraud is no longer the work of lone actors exploiting isolated weaknesses. In today’s digital economy, financial crime has evolved into a...

Elizabeth Travis
Nov 21, 20254 min read


The Age of Fakery: Financial Crime in an Era of Deception, Disruption & Deregulation
We are living through a profound transformation in the architecture of risk. The convergence of deepfake technologies, generative...

Elizabeth Travis
Nov 14, 20256 min read
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