Developing an effective AML and sanctions programme

July 2023  |  ROUNDTABLE | BANKING & FINANCE

Financier Worldwide Magazine

July 2023 Issue

Financial crime including money laundering and sanctions violations continues at pace across the globe, undermining financial systems, impeding economic growth and causing huge losses. In response, authorities worldwide are introducing stricter anti-money laundering (AML) measures to force companies to respond to evolving risks, improve their detection and prevention programmes, and maintain compliance with regulatory requirements. With this dynamic and vigilant approach to the ongoing battle against financial crime, companies need to understand the true identity of the entities and individuals with whom they do business.

FW: How would you summarise recent trends in financial crime? To what extent are the associated risks for companies increasing and growing more complex?

Robertson: For a number of years, the increase in financial crime has outpaced enforcement activity in the UK. A recent strategy document published by the government noted that fraud now accounts for over 40 percent of all offences in England and Wales. Sanctions risks are also greater than they were just over a year ago given the significant change in the sanctions landscape since Russia’s invasion of Ukraine, and the introduction of strict liability for civil sanctions breaches to bring the UK more in line with the more assertive approach to enforcement in the US. These risks will continue to grow for companies, particularly as sanctions are tightened and new legislative developments arise, such as the new ‘failure to prevent fraud’ offence in the UK, which will hold organisations to account if they profit from fraud committed by their employees.

Wang: In recent months, we have seen record-breaking fines imposed by multiple US authorities for violations of sanctions and similar crimes. The Bureau of Industry and Security levied a $300m fine, the agency’s largest standalone administrative penalty, on Seagate for its dealings with Huawei. The Department of Justice (DOJ) criminally charged British American Tobacco and fined it $629m. That was the single largest North Korean sanctions penalty ever imposed by the DOJ. Over the past year, the DOJ’s KleptoCapture, an interagency law enforcement task force dedicated to enforcing Russian sanctions, has seized over $500m of Russian oligarchs’ assets. Through such record fines and seizures, regulators are sending clear signals of heightened enforcement, and likewise the heightened costs of non-compliance. It is noteworthy that recent enforcement actions often targeted activities of non-US companies. The extraterritorial nature of these enforcements further complicates the compliance efforts of multinational companies.

Simmons: Financial crime trends continue to evolve at pace, especially with sanctions violations, drug trafficking, human trafficking, fraud scams and bribery and corruption. The globalisation of financial markets is making cross-border fund movements easier, including for illicit transactions, so tracing and prosecuting offenders is harder. As a result, the risks associated with financial crime have grown in scale and complexity. In turn, this requires companies to review their risk management systems and practices, look for ways to improve effectiveness and efficiency in detecting and preventing suspicious activity, and search for innovative technologies to help manage workloads, alerts and case investigations.

Sengupta: The war in Ukraine has led to the mobilisation of enormous resources to combat sanctions violations across Europe and the US. We are also seeing significant cooperation between regulators and prosecutors across jurisdictions in attempting to trace, freeze or eventually confiscate laundered or sanctioned assets, which may also be linked to corruption or other offences. Although coronavirus (COVID-19) pandemic relief programmes have now tapered off, fraud related to these extensive measures continues to attract enforcement actions in the US and Europe. Finally, the continued rise of cryptocurrencies has created new opportunities for bad actors to commit financial crimes, launder money or avoid sanctions.

FW: Could you highlight any key regulatory developments affecting anti-money laundering (AML) and sanctions? Are companies operating under heightened scrutiny in a frequently changing landscape?

Wang: On the anti-money laundering (AML) front, the new regulation that everyone in the US is bracing for is the Beneficial Ownership Information Reporting Rule under the Corporate Transparency Act, which will become effective in 2024. This new regulation establishes reporting requirements not just for financial institutions (FIs), but for all companies doing business in the US, absent an applicable exemption. The Enablers Act, if passed, would also have far-reaching implications by extending many AML requirements to professional service providers, including accountants, lawyers and investment advisers. On the sanctions and export control front, we are seeing increasingly elaborate sets of rules governing extraterritorial application. A good example is the foreign direct product rule under export administration regulations. What used to be an obscure rule applicable only to a small number of highly sensitive items has, over the two years, expanded significantly to cover many Russia and Belarus exports, semiconductor manufacturing items in China and various entity list companies.

Simmons: Authorities worldwide are actively implementing stricter measures to counter illicit financial activities and sanctions violations. In the European Union (EU), 10 sanctions packages have been issued since February 2022, with an 11th expected later this year to likely focus on anti-circumvention. In the UK, the Economic Crime Plan 2023-26 was issued in March 2023 followed by the three-year UK Fraud Strategy in April, and in May, new sanctions against Russian energy, metals, defence, transport and financial sectors were issued – all looking to tackle various aspects of economic crime, sanctions, company registries, information and intelligence sharing, fraud and scams. Regulators and lawmakers are also focusing on crypto and central bank digital currencies (CBDCs), and this will impact how AML obligations and control practices function. Companies must keep pace with changing regulations to ensure they understand upcoming requirements, make necessary adjustments to their systems, workflows and policies in time, and meet the strictest global requirements.

Sengupta: In 2020, the US Congress passed the Anti-Money Laundering Act, which aims to help FIs detect and report suspicious activity involving money laundering and terrorist financing. The EU has seen the establishment of the European Anti-Money Laundering Authority (AMLA), along with stronger AML prevention, detection and enforcement mechanisms in the 6th EU AML Directive (6AMLD). We have seen growing efforts to create and strengthen beneficial ownership databases globally, along with expansion of AML obligations on art and antiquities intermediaries. Following Russia’s invasion of Ukraine in February 2022, US lawmakers immediately began adopting comprehensive sanctions measures with the aim of limiting Russia’s ability to participate in the global economy. By early 2023, the EU had published its 10th sanctions package, along with enhanced enforcement resources. The rapid adoption of EU measures in non-member countries like Switzerland has put significant pressure on sanctions targets. Legislators and regulators have also maintained their focus on the virtual currency industry, including taking action against illicit players using digital assets to circumvent AML and sanctions laws.

Robertson: Regulatory authorities are becoming increasingly focused on sanctions circumvention. Recent UK designations focused on persons who enable sanctioned Russian oligarchs to hide their assets in complex financial networks. The UK recently published guidance on trade sanctions circumvention which highlighted particular risk factors and encouraged robust due diligence standards in order to prevent the undermining of trade sanctions and export control measures. We expect the upcoming EU sanctions package to have a similar focus. Companies operating in industries particularly susceptible to facilitating sanction evasion – such as investment advisers, estate agents and accountants – may find themselves under increased scrutiny by regulators. This is especially the case where firms are already under increased scrutiny from an AML perspective. A recent ‘Dear CEO’ letter from the Financial Conduct Authority (FCA) in March 2023 to payment firms reminded them of the FCA’s expectations regarding AML and sanctions.

Sharp: The last two years have seen significant changes across the economic crime landscape. Most notably, the UK’s Economic Crime Transparency and Enforcement Act 2022 greatly increased the application of financial and trade sanctions following Russia’s invasion of Ukraine. Companies need to routinely screen their customers against the sanctions list, as it can and does change daily. The planned Economic Crime and Corporate Transparency Bill drives further regulatory change, including a substantial reform of company registration. Things are likely to go further still with proposed measures such as a ‘failure to prevent’ economic crime, bringing a much wider range of businesses into the world of AML.

FW: How would you describe the authorities’ monitoring and enforcement activity on AML and sanctions matters? What problems may arise for multinational companies as a result of the extraterritorial reach of certain laws, and greater collaboration between national agencies?

Simmons: Authorities have intensified their monitoring and enforcement efforts for AML and sanctions. Results are evident in the volume of reported breaches, violations and fines issued globally in the last six months, and increased cooperation between jurisdictions, such as between the UK’s Office of Financial Sanctions Implementation (OFSI) and the US’ Office of Foreign Assets Control (OFAC). Country-level risk and regulations remain a challenge for multinationals, which must navigate various requirements and adhere to these where they operate. Often, the ‘devil in the details’ on how to execute cross-border requirements to remain compliant causes compliance teams the most frustration. This will likely continue, especially with the number of regulatory changes and expectations set to happen in 2023-24.

Sharp: Tackling economic crime, AML and ensuring and enforcing sanctions must be a joint venture across sectors. Regulation done proportionately and sensibly is ultimately good for businesses, as well as national economies. Part of this venture includes increased cooperation between supervisory authorities, both domestically and internationally. The UK’s continued harder-edged approach should reassure compliant businesses they are not operating in an unfair and unbalanced environment, and that those circumventing the rules are dealt with quickly and effectively.

Robertson: Currently, the UK’s enforcement of sanctions is not keeping pace with the raft of measures being introduced. We expect that will change over the next year. The extraterritorial reach of sanctions and close coordination between sanctions and AML regulators, particularly in the US, EU and UK, raises particular risks for multinational companies to consider. UK government guidance on sanctions enforcement is clear that – although a connection to the UK is required in order to engage the authority of the UK regulator – a breach does not have to occur within UK borders; such a connection to the UK might be created by the actions of a local subsidiary of a UK company, or actions taking place overseas but directed from within the UK. In such circumstances, multinational companies must ensure they are cognisant of the broad reach of sanctions, and ensure they have adequate processes in place to manage these risks.

Sengupta: Three draft pieces of legislation relating to the financial provisions of the EU’s AML and combating the financing of terrorism (AML/CFT) policy have advanced through the EU’s procedural system. The package includes the EU’s ‘uniform regulation’, with provisions on customer due diligence, beneficial owner transparency and the use of anonymous instruments, and the 6AMLD, containing provisions on supervision and financial intelligence units, as well as on competent authorities’ access to necessary and reliable information, such as registers of beneficial owners and assets stored in free zones. Finally, the regulation establishing the European AMLA with supervisory and investigative powers to ensure compliance with AML/CFT requirements is expected to lead to superior coordination.

Wang: Governmental authorities are increasing their effort to crack down on evasion through third-party intermediaries. Enforcement agencies across the AML, sanctions and export control spheres have jointly released guidelines that identified common red flags of evasion. They named specific types of companies, such as distributors and forwarders, that the regulators believe are in the best position to detect evasion activities and highlighted the need for all of them to exercise heightened caution and due diligence. The US is joining forces with allies to target financial facilitators and sanctions evaders. In April 2023, OFAC announced it had coordinated with the UK in identifying a global facilitation network acting on behalf of Alisher Usmanov, an Uzbek/Russian oligarch. This collaboration resulted in the imposition of sanctions on companies across 20 jurisdictions. Multinational companies must be more vigilant when dealing with third parties to ensure they are not facilitators of illegal transactions or evasion.

FW: What steps should companies take to ensure they have adequate processes and policies in place to support AML and sanctions compliance?

Robertson: As part of an effective compliance programme, companies should ensure they have adequate risk assessment procedures in place which properly account for AML and sanctions risks. Such risk assessments should be proportionate to the particular risk profile of the company and take into account any particular risk factors which may arise as a result of the specific nature or geography of the company’s operations. More generally, companies should ensure that they consistently keep their sanctions and AML training programmes and policies up to date. Inconsistencies across different jurisdictions’ sanctions frameworks has made compliance particularly complex and so, for multinational companies in particular, it is crucial that robust sanctions compliance programmes are in place and regularly maintained. Understanding to whom sanctions apply is critical and it does not suffice to check names on a country’s designated list. For example, certain UK measures can apply broadly to ‘persons connected with Russia’.

Sengupta: Expert legal advice in multiple jurisdictions is needed to understand applicable AML and sanctions legal regimes in every country where the company operates, which must be updated periodically to reflect regulatory guidelines, industry benchmarking and evolving risks. Processes and policies should be adapted to the risk profiles of various group entities based on factors such as geography, size, volume of transactions and sector of activity. Periodic risk assessments, which can be required under certain local laws, are a critical element of an effective AML/CFT and sanctions programme. Effective customer due diligence is equally important in being able to identify higher risk customers and understand the nature of the business relationship. Effective training to employees, especially frontline employees who are interacting with customers and third parties, is equally important in identifying, investigating and resolving potentially suspicious transactions.

Wang: If they have not done so already, companies should consider conducting a thorough compliance assessment to identify risk points associated with their business, customers and products in light of the recent regulatory and enforcement developments. Such an assessment should be sure to cover any foreign subsidiaries’ operations, companies’ end uses and end users, and any use of third parties. The assessment results can help to guide companies in developing or revising their risk-based compliance programmes, including counterparty screening processes, customer due diligence, and internal controls and monitoring. No policy can be effective without adequate resources for implementation. In a recent action against Bittrex, a virtual currency exchange, authorities faulted Bittrex for relying in some cases on only “two employees with minimal AML training and experience” to review suspicious transactions. Companies need to evaluate whether their compliance function is sufficient to ensure proper training and implementation of their policies.

Sharp: Money laundering regulations are clear in what is expected of businesses. This includes a written risk assessment, tailored to each company’s specific circumstances. There are examples of this online, although no two risk assessments will be quite the same. Companies must consider a range of factors. This includes where their customers are located, the channels in which they transact and whether they use face to face or remote transactions, to highlight but a few. These risks should be noted and mitigated by implementing written policies, controls and procedures. This will help businesses and their staff take the right action when faced with a potential risk, remain AML compliant and ensure they have considered any sanctions that may be in place. All actions taken must be recorded, and the audit trail should be readily available in case the business is inspected.

Simmons: Today, companies cannot afford to delay or ignore reviewing policies and processes. Ensuring adequate AML and sanctions compliance requires key measures, starting with comprehensive risk assessments to identify vulnerabilities and remediation work to address known weaknesses or gaps. Refreshing policies and procedures to align with regulations and good practices is important, as is upgrading system workflows and newer tech to take advantage of the innovations in financial crime detection for greater work efficiency and effectiveness. Companies should educate employees and foster collaboration with regulators and industry peers to gain valuable insights to strengthen compliance frameworks, and scan the regulatory landscape to keep abreast of evolving regulations and adapt accordingly.

FW: In what ways can companies utilise technology to help manage risks arising from AML and sanctions? What tools are available to detect unusual behaviour and identify red flags, for example?

Sengupta: AML and sanctions risks faced by companies will naturally vary based on their sector of activity and role in financial transactions, so the technology needs can vary enormously. Global FIs already subscribe to transaction monitoring and filtering software which flags potential issues, but they must also continue to invest in evolving artificial intelligence (AI) technology to automate detection of increasingly complex patterns and typologies of financial crimes. Designing compliance programmes that are able to quickly respond to changing risks, such as the dramatic growth in sanctions imposed on Russia or targeted cyber attacks that can weaken internal controls, is key. Compliance programmes have to continually evolve with the assistance of automation to identify creative efforts to contravene such sanctions by using alternative jurisdictions or third-party intermediaries to mask the true destinations, purchasers and sellers of goods and services.

Wang: As screening is key to ensuring compliance in these areas, we have seen companies use third-party solutions that regularly screen customers and relevant counterparties against various watchlists, including sanctions lists from different governments, lists of politically exposed persons, and adverse media and regulatory databases. Automated transaction monitoring is another tool that helps identify suspicious activities and anomalies in real-time, so companies can conduct further investigation if necessary. Many such tools are now also incorporating AI-powered functions, which can be tailored to an individual company’s business. They are often used to analyse large sets of existing company data to identify hidden patterns or relationships that can better detect red flags or rule out false positives.

Sharp: There is plenty of technology and many specialist companies offering to help manage AML and sanctions risks. First and foremost, though, it is important to remember that every business is responsible for its own AML and sanctions compliance. Bringing in an outside source does not offload that responsibility. If a provider is managing a company’s compliance more generally, companies need to make sure they are considering their specific business and tailoring the service, rather than providing something generic. Companies also need to make sure that if they are using someone to carry out the AML and sanctions checks for them, that they meet the standards required and that any records are available to them even after they decide to stop using their service.

Simmons: Technology is an indispensable ally for companies seeking to manage risk effectively. Advanced tools assist in detecting and preventing suspicious activities. Machine learning (ML) algorithms and AI can analyse vast amounts of data, flagging suspicious transactions and identifying patterns of unusual behaviour that may indicate potential money laundering or sanctions breaches in a fraction of the time that older methods required. These technologies can automate the monitoring process, enabling real-time alerts for immediate action. Generative AI (GenAI) applications can add additional help, by summarising known data, finding linked patterns in transaction data, and composing narratives for cases and reporting. Additionally, data analytics can enhance risk assessments by identifying high-risk customers, related parties or regions. By harnessing these technologies, companies can proactively manage AML and sanctions risks, improving their compliance efforts and safeguarding their operations from the detrimental consequences of financial crimes.

Robertson: Given that sanctions regulations are constantly evolving in response to geopolitical events – and that there are various nuances and inconsistencies between international regimes – companies should leverage the use of sanctions screening software to ensure they are appropriately managing sanctions risks, particularly when onboarding suppliers or entering into new third-party relationships. Aside from using technology, companies should also be aware of regulatory guidance which can provide a steer as to particular behaviours or red flags to be aware of. The UK Department for Business and Trade recently published guidance on trade sanctions circumvention which highlighted a number of key risk indicators for companies to consider and tailor their due diligence accordingly. Last year, a number of UK enforcement authorities jointly issued a Red Alert which promotes awareness of the common techniques Russian elites are suspected of using in order to evade financial sanctions.

FW: What essential advice would you offer to companies on improving the efficiency and effectiveness of their AML and sanctions compliance frameworks?

Wang: First, always be on the lookout for new regulatory developments. Given the current geopolitical climate, AML and sanctions regulations are rapidly changing and there is often no advance notice to companies which must then update their compliance programmes to comply. Second, foster a strong culture of compliance internally. Because of the broad range of activities covered by AML or sanctions, they are no longer one person’s unilateral responsibility. Often, early signs of potential problems come from reports made by employees on the ground. Lastly, be vigilant in dealing with high-risk actors and jurisdictions. They are, as we have seen, the ever-increasing focus of enforcement authorities, and companies should consider comprehensive guardrails for any such dealings.

Robertson: It is imperative that companies maintain, and regularly keep under review, a robust compliance programme which includes policies, procedures and training for employees around key risks, both in relation to AML and sanctions, but also more generally with respect to bribery and corruption. Companies should ensure that their compliance programme is well-resourced, proportionate to the particular risk profile of the company and updated as necessary to align with relevant regulatory developments. The ‘tone from the top’ of the organisation should demonstrate the seriousness with which AML, sanctions and anti-bribery and corruption risks are taken by the company. Setting the right tone from the top ensures financial crime risks are understood by senior management and a culture of compliance is promoted throughout the organisation.

Simmons: Improving the efficiency and effectiveness of AML and sanctions compliance frameworks requires a proactive approach. First, companies should prioritise regular and comprehensive risk assessments to identify vulnerabilities and tailor their efforts accordingly. Streamlining processes and integrating technology solutions can dramatically enhance efficiency. Using newer innovative solutions, such as GenAI, ML and graph analytics, can improve effectiveness in detection, assessment, holistic risk profiles and allow AML professionals to focus on riskier activities. Ensuring strong governance and accountability through clear policies, regular training and robust internal controls is an ongoing responsibility, and fosters a top-down culture of compliance. Collaboration with industry peers and regulatory bodies can provide valuable insights and best practices. Finally, maintaining adaptability and staying abreast of regulatory developments is crucial to effectively navigating the ever-evolving landscape of AML and sanctions compliance.

Sharp: It is important that companies do two things: read the guidance and take the time to properly review their framework. There is lots of government guidance as well as guidance from the Joint Money Laundering Steering Group explaining what businesses are required to do. When reviewing your framework, start from the absolute basics. Really understand what the risks are and then develop a clear risk assessment to address them. Once that is in place, everything else should flow from there, as it will be built on stable ground. Policies, controls and procedures should all be based on that risk assessment. If the risk assessment is poor, compliance will ultimately be poor.

Sengupta: Seeking timely legal advice to consider voluntary self-disclosures or seeking licences where there may be doubt as to permissibility can significantly reduce enforcement risks and penalty amounts.

FW: Looking ahead, do you expect the risks posed by financial crime to increase over time? How important is it for companies to continually review their systems and processes in response to evolving risks?

Sharp: Criminals are becoming increasingly sophisticated in eliciting information from customers or businesses and using it to commit fraud, including attacks on the UK Exchequer. Add in the uncertainty of how AI or ML could be abused, and it really reinforces the need for an agile, collaborative response between the public and private sector. Prevention is key here, but some criminals will invariably slip through the net. When this happens, it becomes a race between the criminal using their proceeds of crime and agencies recovering them. In order for this to be successful, both the public and private sector must continually review their systems, processes and capabilities. It is the only way we can effectively tackle money laundering and economic crime.

Simmons: The risks posed by financial crime will likely increase over time, given the current cost-of-living crisis, geopolitical circumstances, supply chain issues and the volume of organised crime groups. Criminals continue to get more sophisticated in exploiting vulnerabilities, leveraging emerging technologies and exploiting gaps in regulatory frameworks. To effectively mitigate these risks, companies must continually review, enhance and upgrade their systems and processes, and have a mechanism in place to properly identify weaknesses, adapt to new threats and implement robust measures. By staying proactive, companies can respond to evolving risks, improve their detection and prevention capabilities and maintain compliance with regulatory requirements. A dynamic and vigilant approach is essential in the ongoing battle against financial crime.

Sengupta: While the explosive growth of AI has enhanced technology designed to fight financial crime, the same advances are also expected to pose significant challenges to financial crime prevention and enforcement in the next decade, especially with regard to identification information. Banking and financial regulators across the EU have taken steps to use technology to secure financial transactions, such as the strong customer authentication obligations under the EU Revised Directive on Payment Services. While measures like these have made financial operations more secure, technological advances have also created new opportunities for fraud by bypassing these protections. The risks of identity theft due to AI advances have grown considerably. Companies will need to continue to allocate bigger budgets to technological tools focused on prevention and monitoring, to counter the evolving risks of financial crime.

Robertson: The steady increase in financial crime has continued to outpace enforcement activity in the UK. In particular, against a backdrop of increasing fraud activity, the UK’s Serious Fraud Office (SFO) opened fewer new cases in 2021-22 than it did in 2020-21. However, a new bill – which aims to build on existing financial crime legislation – is currently navigating its way through the UK parliament and is expected to come into force this year. Among other reforms, the bill introduces significant enhancements to the investigative powers available to the SFO to combat money laundering and economic crime. Together with the expected increase in sanctions enforcement activity, it is clear that, now more than ever, companies should take the opportunity to ensure their systems and processes are able to appropriately manage the financial crime risks they face.

Wang: Lawmakers are legislating additional tools to address financial crime issues beyond the traditional financial and economic sectors. The recent Protecting American Intellectual Property Act, for instance, authorised the US government to impose sanctions for theft of trade secrets without the need for judicial findings as a predicate. An outbound investment review, or so-called ‘reverse-Committee on Foreign Investment in the United State (CFIUS)’, is set to take shape soon and will regulate the outbound flow of US capital. Efforts to comply with US sanctions and controls may be complicated or compromised in places such as China and Russia by local anti-sanctions or anti-espionage laws. The Chinese government, for example, has this year raided consultants and other foreign companies engaged in fact-gathering on subjects viewed by the Chinese government as undermining or threatening its national security. In performing due diligence in some countries, particularly China and Russia, companies face growing challenges and risks.

As deputy director of economic crime in the fraud investigation service at HMRC, Nick Sharp leads 800 financial investigators and anti-money laundering (AML) supervisors – the largest dedicated workforce purely focused on economic crime in HM government. His mission is to help reduce the impact of serious fraud on the UK’s tax system, recover the proceeds of fiscal crime and protect the UK against the risk of money laundering and terrorist finance.

Joydeep Sengupta is a member of the compliance, investigations and regulatory team within the litigation and dispute resolution department of Mayer Brown’s Paris office. He focuses on cross-border litigation, compliance and enforcement matters for financial institutions and corporations, including the resolution of administrative and enforcement proceedings involving regulators and prosecutors. He has also conducted internal investigations around the world, including in France, Japan, Italy, Luxembourg, Singapore, Spain, Switzerland, the UK and the US. He can be contacted on +33 6 89 66 01 02 or by email: jsengupta@mayerbrown.com.

George Wang is a litigation partner with decades of experience representing companies, boards of directors and individuals in large, complex commercial cases and other ‘bet the company’ matters. As co-head of both the firm’s international trade regulation practice and Asia litigation practice, he focuses on securities litigation, contract disputes and US trade controls. He has defended over 30 securities class actions for many of the nation’s largest companies. He can be contacted on +1 (212) 455 2228 or by email: gwang@stblaw.com.

For more than 25 years, Elizabeth Robertson has advised on multijurisdictional business crime and regulatory matters, and has played a role in many of the most important criminal and regulatory investigations in the UK. Ms Robertson’s decades of experience have given her significant understanding of the priorities of the UK prosecuting authorities, including the Serious Fraud Office, the Financial Conduct Authority, HM Revenue and Customs and the Competition and Markets Authority. She can be contacted on +44 (0)20 7519 7115 or by email: elizabeth.robertson@skadden.com.

Charmian Simmons is a financial crime and compliance expert for financial services covering the EMEA region at SymphonyAI Sensa-NetReveal. She has over 20 years of experience in the financial sector across risk management, financial crime, internal controls and IT advisory. She is responsible for providing practitioner expertise, thought leadership and analysing key policy, regulatory and technology drivers transforming the compliance market. She can be contacted on +44 (0)20 8152 5940 or by email: charmian.simmons@netreveal.ai.

© Financier Worldwide

THE PANELLISTS

Nick Sharp

HMRC

Joydeep Sengupta

Mayer Brown

George S. Wang

Simpson Thacher & Bartlett LLP

Elizabeth Robertson

Skadden, Arps, Slate, Meagher & Flom (UK) LLP

Charmian Simmons

SymphonyAI Sensa-NetReveal