In this episode of Integrity Insights, our host Filip Brokes engages in a deep dive with Lana Schwartzman, Head of Regulatory and Compliance at Notabene, into the evolving landscape of cryptocurrency regulation. With over two decades in compliance, including 13 years specializing in crypto, Lana shares her expertise on the implications of the EU's Transfer of Funds Regulation (TFR), the travel rule, and the challenges of compliance in the crypto space. Whether you're in financial services, compliance, or crypto, this episode is packed with insights you should not miss.

Show Notes

Introduction

• Lana Schwartzman’s background and journey into crypto compliance.
• Overview of Notabene and its role in crypto transaction compliance.

Crypto and Money Laundering

• Debunking myths: less than 1% of crypto transactions are illicit.
• Comparisons between crypto and fiat in laundering activities.

Techniques Used for Crypto Money Laundering

• Mixers, tumblers, and chain hopping.
• Privacy coins like Monero.
• Regulatory challenges and enforcement efforts.

The Travel Rule

• Origin and purpose of the Financial Action Task Force’s (FATF) travel rule.
• How the rule prevents illicit transactions before they occur.
• Key milestones: U.S. implementation since 1999 and EU's December 30 deadline.

EU’s Transfer of Funds Regulation (TFR)

• Comprehensive requirements for Crypto Asset Service Providers (CASPs).
• Verification of unhosted wallets and self-declaration methods.
• Role of the European Banking Authority (EBA) in shaping guidelines.

Global Landscape of Crypto Regulation

• FATF report: 89% of jurisdictions implementing travel rule compliance.
• Closing regulatory loopholes across regions.
• Industry-driven pressure for travel rule adoption.

Effectiveness and Future Trends

• Indicators of success: SAR filings and increased enforcement actions.
• Predictions for harmonization of global crypto standards.
• Anticipated regulatory scrutiny and cross-border collaboration.

Resources Mentioned

• Financial Action Task Force (FATF)
• European Commission AML Directives
• ALL AML Infobrief
• Notabene’s EU Deep Dive Course

Connect with Us:

• LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=true
• Berlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=true
• Website: https://berlinrisk.com/

Episode Title: AML/CFT Regulatory Roundup of 2024 – Integrity Insights with Jennifer-Hanley Giersch

In this information-packed episode of Integrity Insights, host Filip Brokes welcomes managing partner of Berlin Risk and ALL AML Jennifer-Hanley Giersch for a comprehensive year-end review of the key developments in Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations for 2024. They cover everything from enforcement actions and regulatory updates to sanctions, cybercrime, and terrorist financing. If you work in compliance, risk management, or financial crime prevention, this episode is a must-listen to prepare for the challenges ahead.

Show Notes

• Introduction
  A look back at the podcast's history and this episode's focus on the regulatory landscape.
• Enforcement Actions
  • Key fines in the U.S., Europe, and beyond.
  • Discussion of significant cases like TD Bank and Commerzbank.
• Regulatory Developments
  • EU AML/CFT Regulation updates, including the AMLA.
  • Expansion of obliged entities to crypto services, luxury goods, professional football clubs and more.
• Sanctions Highlights
  • EU sanctions related to the war in Ukraine.
  • Notable sanctions circumvention cases.
• Terrorist Financing
  • Impacts of the Israel-Palestine conflict on financial regulations.
  • Crypto's role in terrorist funding and OFAC's actions.
• Cybercrime and Financial Crime Nexus
  • EU Digital Operational Resilience Act (DORA) and its implications.
  • Global efforts to combat cybercrime, including a new UN convention.

Resources Mentioned:

• Financial Action Task Force (FATF): www.fatf-gafi.org
• European Commission AML Directives: europa.eu
• UN Draft Cybercrime Convention: UN Cybercrime
• ALL AML Infobrief: https://allaml.eu/en/2024/11/11/der-aktuelle-infobrief-von-all-aml-2/

Timestamps

1. [00:00] Introduction
   • Welcome and overview of the episode's focus.
2. [2:00] Enforcement Actions
   • Major fines in the U.S. (TD Bank) and Europe (Commerzbank, Solaris).
   • Key trends in enforcement.
3. [6:25] Regulatory Developments
   • The EU AML Policy Package.
   • Expansion of obliged entities.
   • Impacts of AMLA’s establishment.
4. [16:00] High-Risk Third Countries

• FATF List
• EU List

1. [20:30] Sanctions Updates
   • Key EU sanctions packages in 2024.
   • Notable cases of sanctions circumvention.
2. [26:00] Terrorist Financing
   • Hamas-related financial networks.
   • Crypto and its role in terrorism funding.
   • New EU and U.S. actions against far-right groups.
3. [32:15] Cybercrime as Financial Crime
   • Connection between cybercrime and money laundering.
   • EU DORA and global cybercrime regulations.

Connect with Us:

• LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=true
• Berlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=true
• Website: https://berlinrisk.com/

Podcast Shownotes

Episode Title: From Moscow to Limassol: The Financial Pathways of Russian Migrants

Host: Filip Brokes

Guest: Aron Ouzilevski, journalist, Russia and post-Soviet studies expert, and Fellow at the Institute of Current World Affairs

Episode Summary: In this episode, out host Filip Brokes interviews Aron Ouzilevski, a journalist with expertise in Russian studies and post-Soviet affairs. Aron shares insights from his two-year fellowship with the Institute of Current World Affairs, where he focused on Russian wartime immigration following the Ukraine invasion. Based primarily in Tbilisi, Georgia, Aron has reported on the dynamics behind Russian migration to countries like Armenia, Kazakhstan, Serbia, and Cyprus, investigating the factors that motivated these relocations, from political opposition to career preservation amidst sanctions.

Key Discussion Points:

1. Introduction to Aron's Fellowship:
   • Background in journalism and Russia studies.
   • Fellowship at the Institute of Current World Affairs focused on Russian wartime immigration.
2. Russian Migration Since 2022:
   • Overview of the three main groups of Russian immigrants since the Ukraine invasion:
     • Political dissidents opposing the war and Putin’s regime.
     • Professionals seeking to avoid career isolation due to sanctions.
     • Men avoiding mobilization after Russia's 2022 draft orders.
3. Cyprus as a Hub for Russian Immigrants:
   • The historical attraction of Cyprus for Russian oligarchs and business elites.
   • Impact of the discontinued "golden passport" scheme.
   • Post-2022 immigration trends, including tech employees from companies like InDrive relocating to Cyprus for stability.
4. Financial Movement and Real Estate Transactions in Cyprus:
   • Aron discusses a complex process Russians use to transfer assets via cryptocurrency, bypassing direct bank transfers due to international sanctions.
   • Example of "Misha," a cryptocurrency money mover who assists clients in transferring rubles from Russia to Cyprus through Telegram.
   • The practice of partial crypto payments for real estate and its implications for financial transparency.
5. Challenges and Observations on European Regulations:
   • Cyprus under scrutiny from the EU for money laundering risks.
   • The persistence of Russian entrepreneurs on the island despite regulatory crackdowns.
6. Future of Russian Exile in Europe:
   • Insights into the adaptability of Russian entrepreneurs facing sanctions.
   • Speculation on future destinations for Russian immigrants facing restrictions in Cyprus.
7. Upcoming Projects:
   • Aron shares that he’s nearing the end of his fellowship, with his final dispatch covering the Russian exile movement in France, a nation historically significant for Russian dissidents.

Related Links:

• https://www.icwa.org/russians-exiles-cyprus/
• https://www.icwa.org/current-fellows/aron-ouzilevski/

Connect with Us:

• LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=true
• Berlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=true
• Website: https://berlinrisk.com/