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Project Financial Crime

Delivers community-driven solutions to address the problems pose by digital and financial criminal activity, and positions the EPA and its members as leaders in tackling financial crime

Project Objectives

  1. To raise awareness of the impact of financial crime on the public, consumers and businesses and the importance of combating it through policy statements and thought leadership
  2. To enable the payments industry to mitigate and reduce financial crime by:
    • Analysing the weaknesses in current processes, practices and available data
    • Identifying barriers that inhibit the payments industry in successfully reducing financial crime and how they may be overcome
    • Overturning legacy thinking about compliance and ensure best methodologies are deployed by highlighting best practice
    • Identifying types of behaviour which are indicative of financial crime
    • Identifying where technology can help the payments industry meet both commercially for example to onboard customers more easily, and reduce financial crime whilst meeting legislative requirements
  3. To work with enforcers of AML on the importance of their role and its societal impact and influence their policies and work plans e.g. to persuade regulators to issue relevant and practical guidance such as explaining “The risk-based approach” versus tick box

Project Activities

a)     Whitepapers

One of the first deliverables produced by Project Financial Crime will be the production and publication of a whitepaper, titled ‘The Changing Face of Financial Crime’. Authored by Huntswood, the report will highlight the findings of our research that will include:

Project Financial Crime Team


Jane Jee – CEO, Kompli-Global


John Davies – CEO, The Just Loans Group


Victoria Preece – Compliance Manager,allpay
James Richardson – Head of Market Development – CFRM, Bottomline Technologies
Sarah Rutherford – Solutions Marketing Manager, FICO
Darren Pascoe – European Head of Compliance, Fleetcor
Julian Dixon – CEO, Napier
Phil Creed – Head of RegTech, fscom
Debra Linge – Group Fraud and Financial Crime, Lloyds Banking Group
Terrence Green – Payment Fraud & Risk Manager, NatWest
Danielle Herndon – Head of Compliance & MLRO, Paybase
Jonathan Jensen – Commercial Director IDV, GBG
Che Sidanius – Global Head of Financial Regulatory & Industry Affairs, Refinitiv
Karen Quinn – Head of Marketing, AimBrain
Simon Rodway – Pre-Sales Solution Consultant, Entersekt
Gary Pine – Chief Product Officer, W2 Global Data Solutions

  • Desk research (informed by Thomson Reuters’ survey, ‘The True Cost of Financial Crime’)
  • Qualitative depth interviews (comprising of individuals from across the payments ecosystem including subject matter experts, users, institutions and syndicate members)
  • A half-day scenario planning workshop, in which vulnerabilities within the payments process are identified and different ‘what if’ scenarios are explored
  • Quantitative research focussing on threat responses and the forthcoming changes to fraud reporting in the UK

These findings will then be synthesised into an authoritative and accessible whitepaper containing clear recommendations and proposed policy statements.

The report will be published and promoted at the World Economic Forum Annual Meeting in Davos-Klosters in January 2019. The cost of this Whitepaper will be covered by members of the syndicate, not this project’s budget.

b)     Information Sharing

Project Financial Crime will encourage industry collaboration and call for the sharing of information to highlight the changing nature of fraud and the rapid pace of movement. This information sharing will include case-studies (commercial and/or regulatory) that highlight good practice, showcase incidences of poor financial crime monitoring and reporting, and to highlight where manipulation has occurred. The project will highlight data and evidence-based research – either generated from project-produced reports or championing research through thought leadership content.

Project Financial Crime will also act as a communication platform between the payments industry and regulatory bodies, and will share information to both parties.

c)     Digital Identity, Know Your Customer/Customer Due Diligence processes

Project Financial Crime will review current Know Your Customer (KYC) and Customer Due Diligence (CDD) processes to identify where current practices fall short and where improvements can be made in the monitoring process. Processes highlighted include identity and verification, Politically Exposed Person (PEP) and Sanction Checking, and Adverse Media.

Project Financial Crime will champion the importance of digital identity, and assess the impact this will have upon financial and digital exclusion and the extent to which this can be mitigated.

d)     Education

Project Financial Crime will provide guidance to both businesses and consumers. Likely deliverables from this activity may include a guide on best practice for the payments industry when addressing financial crime and providing consumer/business-focused education on the importance of AML

e)     Policy Positions

Project Financial Crime will call for changes to combat financial criminal activity. These changes may include the increased use of technology to

  • identify patterns of financial crime within the payments process,
  • highlight where technology can help
  • call for regulators to provide consistency in regulation on financial crime and to update regulation on financial crime to ensure innovative effective solutions can be deployed as appropriate

Project Financial Crime will provide commentary (where appropriate) on financial-crime related news stories through pre-prepared statements. Through the publication of statements on policy, Project Financial Crime will likely engage with both the payments industry and national press.

f)      Stakeholder Engagement

Project Financial Crime will engage with key regulatory and governmental bodies to champion the industry’s concerns and to drive beneficial change on regulation and policy.

Project Financial Crime is supported by our Benefactor: