Fighting financial crime together

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Speech by Philip Robinson, Financial Crime Sector Leader, FSA
FSA Financial Crime Conference
15 November 2005

Introduction

We’ve heard today about how Government, law enforcement, FSA and the industry are working together to fight money laundering and fraud. In this closing address I want to talk about the FSA's role in the fight against financial crime, what we have been doing in the last year, what we know about the risks and where we will be going in the months ahead.

I want to look particularly at money laundering, and how we will all meet the challenge of turning the theory of a risk based approach into a working reality. I believe we are approaching the point where we can together really press ahead and build a system that delivers a significant impact on crime with a proportionate investment of time and effort.

Understanding the risks

Let me first step back and focus on risk. The FSA's Chairman spoke earlier of our whole hearted commitment to being a risk-based regulator, meeting our statutory obligation to be proportionate. But proportionate to what? What exactly are the financial crime risks that firms are exposed to, how big are they, and how successful are they at mitigating them?

£25 billion per year is the Government’s best estimate of the amount of money laundered in the UK each year. That money laundering occurs, is not in question. Crack Cocaine from South America is sold here, and the money to pay for it goes back to the South American producers. And there are retail dealers, wholesale suppliers, importers and producers, all of whom pass drugs one way and money the other, just like any other business, So where is this money going? And how much of it is flowing through your firms? Profits are extracted at every stage in the supply chain. Not all of those profits are reinvested in the drug business, some are used for daily living by the criminals, some are spent on luxury living, some are saved for a rainy day, some are spent on school fees, some are invested for retirement. So if this is the case, which of your products do the criminals use? And what does this real multi layered laundering actually look like?

We all realise the difficulties here. If it were easy to get create real intelligence to pass to the industry, law enforcement would have been doing it for years in response to your repeated requests. Nevertheless, much work is now going on to improve things. Let me give some examples.

First Sir Stephen Lander and his top management team at the Serious Organised Crime Agency have been making it clear that they have an intention to share information as widely as possible. SOCA will have unprecedented powers to do this. This will be important across the all aspects of organised crime. But it will be particularly important in enabling the regulated sector to play a more effective role in the fight against money laundering. Other than the criminals themselves, law enforcement can get the best insight into how criminals operate their businesses, and what criminals do with their money. So SOCA will have the information, and the expertise to investigate and analyse what the crooks are up to. When they can combine their expertise with that of the industry, who know their products and how they could be abused, we should be on the way to having the intelligence led regime we all want, focussing efforts in the right place, delivering real financial crime reduction outcomes.

SOCA will build on the efforts already being made by NCIS in this area. This year we have seen a number of NCIS intelligence products published for industry use, and there are more in the pipeline. NCIS staff are also out on the road, talking to the industry about the laundering typologies, and helping to deliver some of FSA's training for the industry.

Many in the industry are finding new ways to target their efforts. In reading the excellent ACPO commissioned report on the SARs regime, written by Matt Fleming of the Jill Dando Centre, I was struck by one of the case studies he reported, and I quote:
'A woman was dealing heroin from her home address and duly convicted. Whilst the confiscation investigation was in progress, a reporting entity read in the local paper about the conviction. A SAR was submitted, and assets were restrained.'

Let me give you some more examples:

one large bank looks at the court orders served upon it by law enforcement; and based on the information it learns from these orders, looks for risk in its other customers with similar characteristics;
another combines and compares internal and external intelligence sources in order to identify suspect transaction and behavioural characteristics;
many of the larger banks also employ data such as lists of stolen passport numbers and from intelligence from law enforcement on Carousel and Tax Credit fraud in order to better identify and target suspect activity.

This sort of lateral thinking and creative use of feedback from law enforcement is exactly what we are all after. It is intelligent use of Intelligence.

Intelligence

I have spoken about firms’ and law enforcement’s efforts on intelligence – but what about us? I am personally committed to the FSA being as active as possible in this arena, with the FSA's intelligence resources reporting up to me. . FSA has a distinctive part to play, using our close relations with both the industry and law enforcement. So, in our current business plan, we are committed to working with law enforcement to develop intelligence on the criminal money flows presenting the greatest risk to the UK.

So, we have strengthened our own Intelligence capabilities, both in skills and in analysis, to help us gather and assess information. We are working closely with our law enforcement partners, not just to understand and analyse their intelligence, but to help them understand what we and the industry need. For the first time we are producing a formal 'FSA intelligence requirement', to inform and measure our own effort and so that our partners understand how their work can help us.

We are building strong links with the SOCA team, and with the organisations that will form SOCA. Increasingly we are engaging, too, with agencies such as the Assets Recovery Agency and the Regional Asset Recovery Teams. And, of course, as Commissioner Hart reported this morning, we continue to work closely with our traditional partners, particularly in the City of London and Metropolitan Police.

We expect all this to help us develop a clearer picture of how criminals use the financial system and where the biggest risks lie. And, as I said earlier, we expect to make as much of this sort of material available to the industry as possible, to enable them to target their own resources most effectively.

Our work on risk and intelligence is focused not just on working with our UK partners. We also take a close interest in the typologies work of the FATF, which looks at trends and themes relating to money laundering and terrorist financing. An important example of this is the work undertaken by one of our insurance supervisors, Mike Thorpe, who led an international project team looking at the vulnerability of the insurance sector to money laundering.

This report was published in June, and its findings were challenging: that the expansion and increasing sophistication of the insurance sector internationally had not been accompanied by changes to firms' money laundering risk management. The report encourages all those involved to reconsider money laundering risks in the insurance sector. The UK has the third largest insurance market in the world, so it is critically important that we all work through the report and see what it has to say for our practices. We in the FSA will be working with the industry and law enforcement to see what lessons we need to learn.

Our aim in all this work on risk is that the FSA's own efforts should succeed in making the UK financial services industry a more hostile environment for serious organised crime, and disrupt their efforts to generate and launder money. Our aim is that the UK's financial services industry is not open for criminal business.

Fraud

Let me turn now to the subject of fraud, and in particular to the progress the industry has made in recent months in fighting fraud. At our financial crime conference a year ago I announced our new policy on fraud: that we would increase our interest in fraud risk management but work with the grain of the market wherever we could, intervening only when we could make a difference.

Since then, we have seen encouraging signs of an increasingly joined-up approach to the fight against fraud, and firms seem to be putting fraud higher up their agendas.

I said last year that the trade bodies have an important role to play in setting standards and providing leadership on fraud prevention. In particular, they are well placed to alert their members, and consumers, to new fraud trends, and how to identify and mitigate their fraud risks. I warmly welcome the publication earlier this year of the Fraud Manager's Reference Guide by the British Bankers' Association, and a similar initiative by the Building Societies Association.

CIFAS, APACS and the BBA have jointly launched an online training package to help businesses prevent identity fraud – an excellent example of working together, and of encouraging good operational practice on the front-line, which is a key element of our work on defusing the ID issue. In addition, the initiative was undertaken in conjunction with the Home Office's Identity Fraud Steering Committee. So this is also evidence of the kind of public/private partnership that we have been seeking to encourage.

We have seen good progress, too, over sharing data on fraud trends. For example APACS is leading an initiative on staff fraud (in which we and other partners are involved), to start collecting reliable data on internal fraud and to identify and disseminate best practice for combating it. And CIFAS is looking at how better to share data about staff dismissed for reasons connected with dishonesty. The ABI has been leading work on tackling fraud in the general insurance industry, and initiatives over data sharing are progressing well. The Insurance Fraud Bureau, scheduled to be up and
running early next year, will be using shared insurance data and new analytical techniques to detect organised fraud, and will take on a co-ordinating role in the subsequent investigations. Pilot projections suggest that firms could prevent frauds costing up to £200 million a year.

I hope this all means that the days where firms see sharing fraud data as damaging to their reputation, or as ceding a competitive advantage to their rivals, are long gone.

I also want to credit the work of the BBA, BSA and the Banking and Building Society sectors following a particular fraud which surfaced in 2004 which demonstrated the risks associated with writing cheques made payable just to a bank or a building society if they fall in to the wrong hands. In a fraud which came to trial, it emerged that a financial adviser had been taking cheques for investments, and asking his clients to make the cheques payable simply to the banks or building societies. He himself had accounts at those institutions and promptly paid those
cheques into these personal accounts. We have been working with the BBA and the BSA on a package of measures to reduce the risk of such a fraud being committed again. I am delighted to say that we have reached an agreement to phase out the acceptance of cheques drafted in this fashion in most situations by October 2006, thus reducing or removing the scope for fraud. We will be working with them on what they should tell customers how best to write cheques to protect themselves from this type of fraud.

I joined other stakeholders last year in calling for the Government to lead on an assessment of what needs to be done on fraud, and then to develop a national fraud strategy. I am very encouraged by the recent announcement of the Fraud Review which the Attorney General mentioned in his speech this morning. FSA is pleased to have a seat on the Review's Steering Group, and we are providing assistance to the Review team. Indeed, as part of that commitment, I am delighted that we have been able to accommodate the review project team in our offices at Canary Wharf.

I hope the review will be the first step towards developing a national fraud strategy, as the Attorney said in the House of Lords on 27 October, that will succeed in reducing the amount of fraud and minimising the harm it causes to the economy and wider society.

Another important development at Government level is the proposed single fraud offence in England and Wales, on course to be enacted early next year. This will simplify the criminal law in relation to fraud, and will send a clear message to the would-be fraudster that prosecution is more likely, and more likely to succeed. For the first time, we have the real prospect of the criminal justice system treating the fraudster as he deserves. The Review is a once in a generation opportunity to make significant improvements to the way we deal with Fraud in the UK. It is essential the the Financial Services industry engages fully with the review and the review team. We will facilitate this, where we can, but I urge all those who have complained to me that they can never get the police to take fraud seriously to put their pen to paper and write to the fraud review team to make their views and suggestions known. As the Attorney said this morning we need to be prepared to ask the difficult questions, and offer imaginative suggestions. To the industry I say – if you don’t kick the ball, you can’t put it in the back of the net. You must engage with the review!

But these encouraging developments could be stymied unless firms make managing fraud risks, like other financial crime risks, an integral part of managing all business risks. So, earlier this year, as part of our Business Plan, I commissioned some work on fraud governance, looking at how the financial services industry manages fraud risk. Initial findings show that fraud is recognised by senior management as presenting a growing challenge and reputational risk to the business. We have seen an example of one bank which has taken steps to tighten up its telephone transfer procedures, and as a result has seen its fraud losses drop dramatically. We have also seen evidence that the abortive £220 million fraud attack about a year ago on the computer systems of a Japanese bank in London, had a salutary effect on other firms, prompting them to assess their own vulnerabilities. This sort of initiative is made possible by firms ensuring that they first collect and then use good management information on fraud risks.

This good practice applies to all firms, not just larger firms or those in one sector. I'm not talking here of disproportionate investment. But fraud can affect any firm. So the message to smaller firms is to learn from work carried out by others (like, for example, the Information Security Project Report the FSA published last year) to benchmark your own organisation against generic risks. Even simpler is for all firms to identify who is ultimately responsible for fraud risk identification and mitigation and whether the reporting lines from and to that individual – or senior management committee - are clear, and known to all staff in the firm.

I hope this gives you a flavour of the initial findings of this important piece of work. We expect to publish the full report on our fraud governance project early in the New Year.

The consumer angle

Moving on to consumer education, the Home Office–led Identity Fraud Consumer Awareness Group, of which the FSA is a member, has built on the success of its identity fraud website with the publication of a poster and leaflet - you will all have seen the stand outside. This has generated great interest. In the public sector copies have been sent to every police force in England and Wales. In the private sector, several firms have asked about "white labelling" the leaflets. More recently the Metropolitan Police has led an Identity Fraud awareness week. Time and again the tabloids run stories on identity theft and how to prevent it. And I find myself both pleased and depressed. The message should be getting through to us all – it can take many hours over several weeks to get your life back on track. Yet still we fail to heed the warnings – being lax with our passwords, not keeping our virus protection software and firewalls up-to-date, failing to shred personal documents and handing our credit cards over in the wine bar.. The consumer message on fraud – that we must all take care to protect ourselves - is one that we all need to keep communicating.

What the FSA has done

I made several commitments in my speech last year about the part the FSA would play in the fight against financial crime. Let me tell you about the progress we have made.

As my Chairman stressed this morning, we have invested a great deal of time and effort in the past few months into creating a new financial crime training package, the first phase of which is being rolled out this week. We well understand that public statements mean nothing unless we back them up in supervisory and enforcement practice. So, when we said in our Business Plan that we would be taking a closer interest in firms' fraud risk management, and when I have said in many speeches that we would ensure that our supervision and enforcement staff would understand the risk-based approach to anti-money laundering controls, we knew that meant providing high quality retraining.

The e-learning package we are rolling out to all our staff will give them a good understanding of what financial crime is, how it affects what we and the firms we regulate have to do, and what sort of controls they should expect to see in a well-run firm. And they'll have to pass a test on it. This e-learning will also be available to firms shortly for just £40, so that they can see our approach for themselves and perhaps also use the material as part of their own training.

In addition to this e-learning package, we will, for the first time, be rolling out in-depth interactive workshops on fraud and money laundering, mainly for our supervisors. We are looking to bring about a step change in our understanding of the financial crime risks in firms, and how they should be managed. This training will be delivered by external specialists with knowledge of financial crime risk management in a wide range of firms.

These new training packages will do much to ensure that our staff have the skills they need to understand fraud and money laundering risks and how firms should mitigate them in a risk-based way.

We have seen excellent progress, across the board, and real evidence of the "partnership approach" I espoused last year. I see a continuing role for the FSA in the fight against fraud. And, consistent with our commitment to working with the grain of the market, we will target our activity in areas where the market is working less well or not working at all. All in all, fraud is higher on our agenda than it was a year ago, though not, I must stress, at the expense of money laundering, and it is to this area that I now turn.

Money laundering

There are two money laundering themes that I wish particularly to focus on:

our commitment to the risk-based approach; and
shifting the emphasis away from policy-making to delivery on the ground.

Over the last few years we have all been working to design an AML regime that delivers much better value for money. 2006 should be an important milestone, and the challenge for us all is to make sure it is.

The risk-based approach

The risk-based approach has always been part of our approach to financial crime, and has increasingly become the driver of all we do. My Chairman spoke earlier, for example, about our review of the Handbook and how we hope this will enable firms to target their resources where they will make the most difference in fighting crime.

Whether or not we do decide to replace the Money Laundering Sourcebook with more general provisions about the role of senior management, what we expect of our firms is clear. Let me recap our four main expectations, all of which hold good whether or not we change our Rules.

First, firms must take their responsibility to fight money laundering and terrorist financing seriously. I have heard it said that the FSA is going soft on money laundering. The FSA's Chairman has already rebutted this today, and I will do so again now. We are not, so do not take your eye off the ball.
Secondly, senior managers must take responsibility for their firm's financial crime risks. The lead, vision, strategy, resources, and risk appetite: they must all come from the top.
Thirdly, efforts should be targeted on risk and should be effective. So a firm needs to know where its risks lie, and how these can best be managed. And it needs to have what I call 'good basics' – a really sound foundation dealing with the low risk customers and products, on which the risk-based approach can then be built.
Finally, the MLRO is the focal point of a firm's AML activities and therefore, central in the fight against money laundering. That is why the MLRO role will remain a controlled function. So my message to the MLRO community is – The FSA sees the MLRO role as crucial, and the system relies on your effectiveness. So you need to have the right skills, resources, technology, powers and access to other senior managers to do your jobs properly. And if you don't, we will want to know why both you and senior management have allowed that to happen.

If anyone hadn't realised the FSA was as concerned as ever about money laundering, I hope our enforcement action last Wednesday against a firm and its managing director made the matter crystal clear. The firm involved was introducing customers to a bank without providing the bank with appropriate information on who the customers were or where their funds came from. As a result, over £8 million entered the UK financial system through a bank which unwittingly did not have the information it needed to manage its risks. We fined the introducer £175,000 and its MD personally £30,000 for serious failings in anti-money laundering compliance.

I reiterated publicly last year that it was our policy to use our enforcement powers in relation to money laundering compliance only when we found evidence of significant failures. This case involved just such a failure. We have always made it clear that it is senior managers who are ultimately responsible for their firm's risk management. Where a firm faces high money laundering risk but they fail to introduce mitigating controls, senior managers can expect to be held personally responsible.

So, it is a key principle for us that AML has to be on the radar of all CEOs and their Boards. Why? Because senior managers can make all the difference. As I have said before in other contexts, we expect senior managers:

to buy into and take ownership of the firm's AML policy and the risk-based approach;
to provide leadership from the top and determine the right AML culture;
to provide strong support, guidance and constructive challenge to the MLRO; and finally
to ensure that they get regular management information keeping them abreast of key issues so that they can make strategic decisions about the firm's AML activities.

Let me come back to the other key anti-money laundering role – the MLRO. The competence and authority of the MLRO is likely to have a substantial impact on the quality of the firm’s anti-money laundering controls. So I was delighted when the Financial Services Skills Council launched a consultation exercise earlier this year on industry-developed national occupational standards for MLROs. These are intended to provide benchmarks for recruitment, performance management, assessment of training needs and so on. We need an MLRO profession that is highly skilled and highly regarded. The Skills Council's work on defining standards should help fuel the welcome debate in the industry on the role of MLROs and how they can best be equipped and trained. Firms already need to ensure they have competent staff, so when the standards are published next year, I hope that all firms will review what they mean for them. Improving the effectiveness of the MLRO must help to improve the effectiveness of the AML regime as a whole.

One of the areas I continue to hear about in feedback from the industry is the so-called 'fear factor', where firms feel compelled to be overly conservative in complying with their money laundering obligations because they fear the FSA taking regulatory action. I've said this before but let me say it again. We recognize that any regime that is risk-based cannot be a zero failure regime.

So we're not after zero failure, what do we want? You have heard both my Chairman and me say today that we expect firms to manage their financial crime risk as they manage other business risks. That means resourcing that activity adequately and putting resources where there is most marginal benefit, against the backdrop of their legal obligations. We are looking for: consistently engaged senior management; high quality systems and controls appropriate to each firm's risk profile; and effective delivery Together, these should produce an effective system.

As I said earlier, we have to make sure that our staff look at firms in a risk-based way: we must practise what we preach. That is why we have been putting much time and effort into the new training package I spoke about. The final piece of the training jigsaw is developing workshops in collaboration with the JMLSG specific to the revised Guidance. The aim of this part of the training is to explain to supervisors the new thinking and risk-based approach in the revised Guidance, and what this means for our supervisory approach. It will also ensure our staff are aware of current AML best practice.

The JMLSG Guidance – a real opportunity

Let me turn now to my final theme today:

I hope that 2006 will be seen as a key stage in the evolution of the UK's regime for fighting money laundering and terrorist finance, as a number of developments come together: the establishment of SOCA, Sir Stephen Lander's review of the SARs regime, and last – but by no means least - the JMLSG's new Guidance. The JMLSG and their members deserve enormous credit for all their work to revise their Guidance. And I cannot let today pass without a very special thank you to Jeremy Thorp of the BBA and JMLSG, who will be retiring soon, and whose tireless work on the new Guidance deserves all our gratitude.

Much that has been spoken about today is likely to be in the new Guidance: the importance of senior management and the MLRO; the need for a risk-based approach; the need not to be petrified by the 'fear factor'; the need to use ID as one, but only one of the AML tools. The new Guidance will be a blueprint for a more focused and more efficient regime, in which firms' internal processes and controls are more appropriately aligned and proportionate to the risks involved.

We regard the Guidance as one of the key elements in the UK fight against money laundering, and as a resource on which all firms can draw in terms of designing their defences and checking that they work. In the past, firms have had to pay for copies of the Guidance Notes, so we have not assumed that everybody will have and use a copy. But the JMLSG have announced that from now on the Guidance will be available free of charge on their website, so much of the cost constraint falls away. I have to say that I find it difficult to see now how firms will be able to maximise their contribution to the fight against money laundering and terrorist financing without at least making reference to the Guidance. So if a firm does not have a well thumbed copy, or whatever is the WWW equivalent of that (!), our supervisors may well want to know why.

But of course knowing the theory takes you only halfway there. We need to shift the emphasis now from theory to practice. The new Guidance is a golden opportunity for firms to review and where appropriate revise their procedures and internal controls: to make life easier for their honest customers and harder for the criminal.

I very much hope firms will rise to the challenge. Firms should already be thinking through what a more risk-based approach will mean for them. And I know some of you are already gearing up to change your ID practices, and will be quick off the blocks when the new Guidance is published. Once the Guidance comes into effect our supervisors are sure to be interested in how firms have responded. So we will, for example, be expecting firms:

to carry out a proper risk assessment and to document their approach to risk and its mitigation;
to deploy all the AML tools – not just ID and KYC, but monitoring and the rest - and to strike the right balance between them;
to consider going beyond initial ID when they take on a customer, by using appropriate KYC when the circumstances warrant it;
to check that their MLRO and senior management are clear as to what the new Guidance means for them;
to ensure that those whose job it is to quality assure a firm's defences – internal audit, risk management teams, and the like - are geared up for the new approach, and
always, to calibrate their actions to their firm's risks.

Turning to ID, the JMLSG will be helping us all 'defuse' the ID issue. They are offering a blueprint which should be more robust, less costly, deliver better value to law enforcement, and achieve stronger consumer awareness and buy-in. So I would expect firms to do a number of things:

To review their ID practices to ensure that they are consistent with the new Guidance. If a firm is adopting a different approach, they will need to demonstrate that it is appropriate given the risks to which they are exposed.
To communicate effectively to customers the reasons for ID and what it involves. There has been good progress, and many firms are doing just this; but we all need to do more. At the weekend I heard of a firm telling a potential customer "you have to show us this list of documents because of the FSA's rules". The real message should be "by providing ID , you are helping in the fight against financial crime and terrorist finance , and we only ask for what we consider we need in your circumstances".
To ensure that there is enough flexibility in their policies and procedures to avoid excluding the disadvantaged from access to financial services. I'll come back to this in a moment.
To ensure high operational standards; and
To consider when they need to use the other AML tools too – KYC, monitoring and so on.

All this – if properly implemented in an informed way - should deliver better value for money as firms focus their efforts to areas of greatest risk.

Before I finish I also want to say a few words about two particular aspects of 'defusing the ID issue': financial inclusion and good operational practice on the front line.

On financial inclusion, I want to make clear that ID checks should not be a stumbling block for law-abiding people seeking access to the financial system, as it has been in the past for a small minority of customers. Thanks to the JMLSG, there will now more clearly be a broad choice of ID options on the menu for those who don't have documents like a passport or driving licence. And with some products there may well not be a need to confirm address. So someone dependent on state benefit may be able to use documents from the DWP; an overseas student might use a passport and a letter from a college; and so on. 99 times out of 100, hopefully more, the law-abiding will be able to prove who they are without undue difficulty. We have done our part, with the defusing the ID initiative; the JMLSG are doing theirs, with flexible new Guidance. Now it is up to firms to deliver their part: first by taking advantage of the new Guidance to have an ID system that is effective in helping deter and detect crime, but causes the minimum of inconvenience to honest customers; and secondly by ensuring that their staff on the front-line are fully aware of this new approach and are equipped to deliver on it.

On the flipside, a defter touch over ID mustn't mean making life easier for the criminal. I talked earlier about 'good basics'. A good example of this is doing ID checks well so that those pretending to be who they aren't don’t slip through the net. Firms need to make sure their front-line staff are equipped to do ID checks well and to be vigilant. Even in volume business it is reasonable to expect them to ask themselves "Is the customer in front of me the person in the passport photo? And has the photo been tampered with?". "Does something not feel right about this on-line application?". It is often front-line staff who are best placed to spot the criminal, and they need the training, the resources and the encouragement to do some basic checks well.

Conclusions

We have heard a lot today about different ways of tackling financial crime. But they had one common theme: we all have a part to play in reducing financial crime, and that in turn will help to reduce crime overall. And we must play our parts well. My Chairman mentioned earlier the very great efforts that the industry is making to assist law enforcement in their investigation of the July bombings. These successful efforts can only be built on a solid foundation. That is why good AML practice and good record-keeping make such a positive contribution to the fight against crime and terror. Events such as the July bombings, and the ability to follow the money trail in the financial records of those involved, help drive the point home.

Given our financial crime objective, the FSA will always take a close interest in the financial crime risks firms face, where they come from and how they can best be managed. As financial crime sector leader, I have been appointed to make sure we do just that.

But we cannot do our job on our own. We will always need, and want, to work with partners in Government, law enforcement and the industry. So the creative ways in which, to take two examples, SOCA are planning to use their new powers and the JMLSG have approached their new Guidance, give us real encouragement that we have more chance of succeeding in the fight against crime in the future.

Firms, too, need to play their part ever more effectively if we are to get more crime prevention and reduction from their investments to target their efforts, confident that the FSA don’t expect zero failure. That is what the risk based approach is all about. As I said earlier, we all need to make 2006 a major milestone in our risk-based journey.

We all have to rise to the challenge the criminals have set us. Let us work to Fight Financial Crime Together and beat them.

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