A melting pot of ideas, inspiration and positive intent – solving the UK’s financial crime problem should be no big drama

In one sequence of the excellent BBC series The Gold, a character explains how the proceeds of the stolen Brinks Mat bullion is laundered through the banking system, depositing up to £400,000 cash per day in a Bristol branch of Barclays Bank, disguised as the profits of a local gold merchant.

“If this country had proper banking laws,” the character quips, “and a bank saw a company suddenly making tonnes of money, they might tell someone. But we don’t, so they won’t.”

What strikes me most is how relatively recently this held true. The heist took place in 1983, but you’d be forgiven for thinking it was far earlier. It just goes to show how far UK regulation and compliance has progressed in a short space of time.

Little wonder when events like UK Finance’s Economic Crime Congress at the Brewery, London on 30 March attract a capacity crowd comprising the who’s who of financial crime prevention from organisations including the House of Lords, Home Office, HM Treasury, National Crime Agency and others.

It's quite rare to come away from an event with quite so much positivity – an almost overwhelming sense that we’re on the right track as an industry. Yes, there’s still much to do, but what’s most encouraging is the wealth of practical actions surfaced from just one day’s discussion. As I journeyed home, I noted some of them:

  • A system-wide leadership is required to tackle the systemic challenge; and a collective, coordinated effort between public and private sectors: government, law enforcement, regulators, industries and charities. The language used to educate the public needs to move away from identifying the victim as the single point of failure.
  • The structure underpinning financial crime prevention should be outcomes-based and purpose led, designed to protect customers and wider society. We must be able to measure success against clear, consistent objectives. For its part, policing of economic crime needs to be proactive and intelligence-led, migrating further online and upstream to disrupt activity earlier in the criminal lifecycle. It must also recognise that criminals do not respect boundaries or borders – we need effective cross-jurisdictional and international agreements to share and act upon intelligence with appropriate urgency.
  • Our governance framework needs also to be dynamic and flexible to changing trends. Regulators and supervisors need to give businesses the assurance that they can safely dial down on low value-creating activities in order to create capacity to dial up on higher value activities and direct effort towards activities that have the greatest impact.
  • This battle cannot be fought alone. Regulation must widen its influence well beyond the financial services sector, to telecoms, technology, social media and others. Tightening the net on the criminals requires the mandated support of all custodians of consumers’ data. The quality of that data and the ability to share it are also absolutely vital. Whilst we welcome the forthcoming amendments to promote better data sharing for crime prevention purposes, the onus must also be on organisations to invest in the right data structure, lineage and retrieval processes to realise the benefit and to support prevention efforts. Bringing fraud and AML functions together will promote collaboration. Emphasis must be on integrating intelligence and datasets and taking a de-siloed approach to people, technology and data. through common governance, assurance and advisory.
  • And culture matters: the will to effectively combat economic crime and protect customers and society from its effects must be a board-level priority and engendered through cultural norms from the top, right through organisations – both in the public and private sectors.

Dramas like The Gold perfectly demonstrate the challenge: criminals operate in highly organised groups, with an established hierarchy, well-rehearsed plans and far-reaching networks. To gain the upper hand, we need to think and act with similar determination and cooperation.

The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

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