Corylated

In this episode, founding editors Rachel Wolcott and Lindsey Rogerson sit down with Adam Cruise, a South African investigative journalist whose work exposes realities of wildlife trade and conservation policy. Adam shares insights from the acclaimed documentary Trade Secret, which uncovers how legal wildlife trade often fuels illegal trafficking, with devastating consequences for species like polar bears, lions, and rhinos.The conversation explores the complex web of international agreements, including CITES (Convention on International Trade in Endangered Species), and the troubling role of euphemistic language such as “sustainable utilization” and “conservation hunting.” Adam reveals how these policies, supported by influential NGOs, blur the lines between protection and exploitation, creating loopholes that organized crime syndicates exploit.Listeners will also learn about the financial crime dimension—how wildlife trafficking intersects with money laundering and poly-criminal networks—and what red flags compliance professionals should watch for. From shocking scenes in Canadian and Norwegian warehouses to the global demand for exotic pets, this episode challenges assumptions about conservation.LinksTrade SecretAdam CruisePolycriminality and pangolins: following wildlife crimes’ tracks in financial servicesGlass eel trafficking connects €3bn money laundering networksContact useditorial@corylated.comwww.compliancecorylated.comwww.corlytics.com

In this week’s Corylated podcast Lindsey and Rachel discuss carbon markets. They begin with the ongoing UN climate conference (COP30) in Brazil and a recap of the current state of CO2 emissions and rollback on sustainable finance rules underway in the European Union. Next, they discuss the alleged $100 million fraud at Cookstove and how it adds to a chequered history of carbon credits. They then move on to outline the financial crime and fraud vulnerabilities of these instruments, as first set out in a 2013 report by INTERPOL and now being explored by the Royal United Services Institute (RUSI). Lindsey then explains the potential behind carbon market initiatives including Carbon Impact X and Carbonplace before the pair discuss how compliance professionals can help mitigate these financial crime risks. LinksGlobal Carbon Budget | GCB 2025Southern District of New York | U.S. Attorney Announces Criminal Charges In Multi-Year Fraud Scheme In The Market For Carbon Credits | United States Department of JusticeScoping Corruption in Voluntary Carbon MarketsContact useditorial@corylated.comwww.compliancecorylated.comwww.corlytics.com

The UK still lacks a new fraud strategy, leaving consumers and businesses exposed to escalating threats. In this episode, Lindsey and Rachel unpack why the lack of government action and explore the blame game between tech giants, financial services and policymakers. Meta faces criticism for enabling fraud through its platforms—but Meta points the finger back at payments providers. Meanwhile, identity fraud is becoming a jigsaw puzzle of stolen data, weak controls, and fragmented accountability. Amid the chaos, Starling Bank stands out as a bright spot with its innovative fraud intelligence tool, proving that thoughtful measures may make a real difference.LinksStarling Bank scam detector tool prompts questions for Ofcom, MetaNew rules proposed to combat SMS scams in UKUK fraud and fincrime information sharing deemed ineffective, clubby Serious abuse of the UK corporate register continues despite reforms Tech firms must be held to account for role in proliferating fraud, incidents surge 17%Contact useditorial@corylated.comwww.compliancecorylated.comwww.corlytics.com

In this episode Lindsey Rogerson, founding editor and Elizabeth Lumley, special correspondent, discuss the newly announced plan for a digital ID – or Britcard -- in the UK. Elizabeth highlights the lack of detail in what the government has announced, and they discuss the politicisation of announcement. The conversation then turns to the digital IDs that already exit in the UK as well as the merits of the numerous examples of introductions of digital IDs by governments in countries including India, Singapore, Brazil, the United Arab Emirates and Estonia. Elizabeth and Lindsey then discuss the bank-led digital IDs initiatives in Norway and Sweden and how a digital ID could help financially excluded individuals to be accepted for banking services.Finally, the pair discuss what the advent of digital IDs has meant for the reduction and prevention of financial crime and fraud. Links Plans around BritCard in the UK are unclear and may be redundant - Compliance CorylatedContact useditorial@corylated.comwww.compliancecorylated.comwww.corlytics.com 

In this episode, Rachel Wolcott speaks with Patrick Tan, general counsel at ChainArgos about the controversial use of blockchain analytics in criminal investigations, focusing on the case of Roman Sterlingov, convicted of operating Bitcoin Fog. Patrick discusses the limitations and risks of relying on blockchain tracing heuristics as forensic evidence, the amicus brief ChainArgos filed in Sterlingov’s appeal. Rachel and Patrick also discuss the Bybit hack and Iranian crypto flows and nested exchanges. Rights to replyChainalysis declined to comment on the ChainArgos Amicus Brief.TRM Labs said it did not see a difference between its analysis and ChainArgos’.Links Amicus Brief in Roman Sterlingov’s Appeal, also available via PACER (U.S. federal court document access system)Chainalysis Blog Post Response: “Chainalysis Data Stands Alone: Independently Proven, Accurate, and Reliable”North Korean hackers’ crypto expertise allows them to steal and launder in plain sight Undercover North Korean IT workers may be driving crypto theftsTRM Labs report on Iranian crypto activityChainArgos’ report on Iranian crypto activity Contact useditorial@corylated.comwww.compliancecorylated.comwww.corlytics.com 

In this week’s Corylated podcast Rachel and Niece discuss yet another failed UK payment service provider and examine the UK Financial Conduct Authority’s recent track record supervising this market segment. As UK PSPs continue to fail, the FCA would like to speed up authorisations. Niece and Rachel wonder about these plans, as well as the lighter touch crypto regimes developing in the US and UK. Also, Niece tells Rachel about “strong views” aired at the recent US Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) crypto roundtable! Links Complaints Commissioner’s report on Firm XFCA statement on Premier FXFCA payments improvement plan not fully implemented, failed firms’ customers £22.5mn out of pocketZiglu’s filings show early regulatory interventionFifth payments firm enters special administration under FCA’s watchUS TradFi criticises ‘innovation exemption’ policiesContact useditorial@corylated.comwww.compliancecorylated.comwww.corlytics.com

In this week’s Corylated podcast Rachel speaks to Neil Giles, president of the TraffikAnalysis Hub at UK charity Stop the Traffik. Neil shares his deep expertise in identifying human trafficking through financial transaction data and using persona-based typologies and survivor-informed intelligence.The conversation explores how financial institutions can detect trafficking patterns, the role of typologies, and why getting curious about this crime can help set someone free. The episode also covers:• The growing market for child sexual exploitation and its financial footprint• Payment service providers and high-risk transactions• The importance of public-private partnerships (PPP) in fighting trafficking• Case studies including Operation Fort and the Modern Slavery Intelligence Network• Why financial institutions should act now without waiting for regulatorsWarning: difficult subject matter.LinksStop the TraffikHuman trafficking transaction detection needs a bigger financial crime toolkitUK watchdog has no plans to prioritise human traffickingEvolving UK people smuggling policy requires new approach from financial crime teamsCompliance CorylatedCorlyticsContact us: editorial@compliancecorylated.com

In this episode Rachel Wolcott and Lindsey Rogerson discuss third quarter enforcement data provided by Corlytics. They begin by reviewing the largest fine of the quarter handed down to fast fashion chain, Shein, by French privacy watchdog Commission nationale de l’informatique et des libertés’ (CNIL). Shein was fined US$175.7 million for multiple breaches of Article 82 of the EU General Data Protection Regulation (GDPR) after an August 2023 investigationproblems with the retailers’ cookies. Rachel then explains the enforcement actions which lie behind a record quarter of fines from the Monetary Authority of Singapore (MAS), before moving on to discuss why anti-money laundering and financial crime are the common theme behind many of Q3’s enforcement decisions.  Finally, they discuss the messages coming from US and UK regulators on future enforcement actions as well as the prospects of more AML-related enforcements from United Arab Emirates. Are enforcements there token gestures or a sign of things to come?  Links:Q3 enforcement: Singapore fines and bans for AML failings; Shein’s costly cookiesMAS Takes Regulatory Actions against 9 Financial Institutions for AML-Related BreachesCookies placed without consent: SHEIN fined 150 million euros by the CNIL | CNILMonzo fined £21 million for fincrime failures, third challenger bank fine inside a yearWeak bank customer due diligence in spotlight again after Barclays fined £42 millionSettlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and Interactive Brokers LLC | Office of Foreign Assets ControlTransparency International Russia (in Exile): “Gold and Crossbows: How Russian Mercenaries Enable Dirty Business in Africa”Acting Chairman Pham Announces Successful Completion of Enforcement Sprint Contact us:Editorial@corylated.comwww.compliancecorylated.comwww.corlytics.com

The Corylated podcast is back with a conversation with Guido Palazzo, professor of business ethics at the University of Lausanne in Switzerland. Guido spoke to Rachel this week about his new book The Dark Pattern.Join Guido and Rachel for a sobering journey through corporate hell exploring the human toll of some of the worst corporate scandals of recent times. Guido and his co-author Ulrich Hoffrage have identified nine traits of the dark pattern and explain how they manifested at companies from Theranos and Wells Fargo to Uber, Foxconn and FranceTelecom—all scenes of serious corporate malfeasance. Finally, Guido and Rachel discuss how ‘The Bright Pattern’ could help organisations fend off such failings. Warning: contains mentions of suicides. Links:The Dark Pattern: The Hidden Dynamics of Corporate ScandalsGuido on LinkedInwww.compliancecorylated.comCorylated on LinkedInwww.corlytics.com

In this episode Rachel Wolcott and Lindsey Rogerson discuss how the US is diverging from the Rest of the World when it comes to expectation on financial crime expectation and the checks it requires financial institutions to make. They begin talking about US Treasury plans to reduce Bank Secrecy Act anti-money laundering obligations for smaller banks. Rachel raises the case of Summit National Bank in Hulett, Wyoming (pop. <400) which had plans to go big in fintech with a Bulgarian crypto company. It did not have ambitious ML/CFT compliance plans, however, and US regulators pulled the plug.Lindsey and Rachel then switch to discussing the recent fines from the UK Financial Conduct Authority on the so-called challenge banks – Metro, Monzo and Starling bank as well as early action against CB Payments. Most of which can be attributed to prioritising growth in customer number of AML and KYC checks. And Lindsey asks what has happened to an essential annual data publication from the Payments Systems Regulator. Finally, they discuss the European Banking Authority’s recent opinion on the state of AML control at European institutions and the UK’s nine System Priorities for tackling financial crime. Links:Main Street banks can have Big City financial crime risksSummit National Bank, Hulett, Wyoming Weak bank customer due diligence in spotlight again after Barclays fined £42 millionMonzo fined £21 million for fincrime failures, third challenger bank fine inside a year - Compliance CorylatedNational Crime Authority System Priorities UK-Nigeria partnership to detect, disrupt and deter fraud - GOV.UKEBA Opinion and Report on ML TF risks.pdf Contact us:Editorial@corylated.com www.compliancecorylated.comwww.corlytics.com 

In this episode Rachel Wolcott and Lindsey Rogerson discuss the proposed changes to the UK’s landmark Senior Managers & Certification Regime (SM&CR). At its inception it was deemed to be framework proportionate to challenge of holding financial services senior managers accountable, but 10 years on the UK government and regulators view some aspects to be a burden. Rachel and Lindsey look back at the post-Global Financial Crisis landscape that brought SM&CR into being, the lack of enforcement action around the regime as well as some of the proposed changes. LinksMore senior manager penalties coming, says UK watchdogFinancial Conduct Authority consultation: https://www.fca.org.uk/publication/consultation/cp25-21.pdf Prudential Regulation Authority consultation: https://www.bankofengland.co.uk/prudential-regulation/publication/2025/july/review-of-the-senior-managers-and-certification-regime-consultation-paperHM Treasury consultation: https://www.gov.uk/government/consultations/consultation-reforming-the-senior-managers-certification-regime Contact us:Editorial@corylated.comwww.compliancecorylated.com www.corlytics.com

In this episode Niece Prayoonrat discusses her recent reporting with Lindsey Rogerson. They begin with failed crypto firm, Ziglu. Niece explains how she first became aware that something might be amiss at the group, before moving on to discuss the uncertainty over whether investors will get any money they had in its so-called “boost deposit account” back. Niece then turns to neo-broker Robinhood’s recent product launch on the French Riviera, and why its regulator – the Bank of Lithuania – has some questions over its Open AI and Space X private stock tokens. They discuss why the regulator’s decision on compliance with the Market in Financial Instruments Directive (MiFID ii) will be hotly watched by financial firms who have a host of alternative asset tokens waiting in the wings. Finally, they discuss Niece’s Freedom of Information request which revealed the Financial Conduct Authority had spent £300k on influence-led campaigns. They highlight risks to the regulator from the discovery that all off influencer paid by the FCA also earn referral commissions from neo-brokers. And discuss how regulators need to be much clearer with the public on if, and how, money in crypto “deposits” and “funds” is protected. Links:Niece’s articlesExclusive: FCA spent over £300k on 23 finfluencer-led campaignsEx-Starling founder’s Ziglu enters special administrationDefunct Ziglu’s finances in doubt last year; directors linked to failed investment firmFCA: firms should tell us before ‘things go wrong’Ziglu’s collapse: UK crypto ‘small fry’ struggle to succeedRegulator seeking clarification on Robinhood's EU stock token launch - Compliance CorylatedFCA creates dedicated ‘neo-broker’ supervision team Library of Congress archive of New York Stock Exchange investment adhttps://www.youtube.com/watch?v=OQrs6Oa8qtE

In this episode Rachel Wolcott and Lindsey Rogerson discuss the jailing of siblings Redinel and Oerta Korfuzi at Southwark Crown Court in London on July 4. The pair were found sentenced to a combined 11 years after Redinel used his position as an analyst at Janus Henderson to trade on inside information. They begin by discussing why the Financial Conduct Authority (FCA) might be a celebratory mood after this and other recent successful insider dealing prosecutions, before considering the details of the judgment and the lessons therein for financial services professionals. The conversation then moves on to ponder the presence of Sottish and Northen Irish bank notes in two recent FCA criminal cases. Finally, they discuss recent warnings from UK and French authorities about organised criminal gangs increasingly recruiting junior bank staff for their access to insider information. And crucially what systems and controls these institutions need to have in place to detect and notify regulators when they suspect insider dealing. Links:Rachel’s article on the Korfuzi case FCA hails Korfuzi siblings’ long insider dealing sentencesFCA Match Watch 77 – Trading by OCGs Market Watch 77 | FCA FCA Match Watch 73 – Market conduct and suspicious trading Market Watch 73 | FCAAMF and French Anti-Corruption Agency (AFA) call for vigilance on OCGs The AMF and the AFA call for vigilance on the risk of private corruption by criminal networks of natural persons with access to inside information | AMFFinnish Financial Services Authority June Newsletter on suspicious transaction and order reports (STORs) markkinat-tiedote-2_2025_en.pdfResponses to the European Securities and Markets Authority (ESMA) paper on insider lists Consultation on the Draft implementing technical standards on the extension of the use of the alleviated format of insider lists

In this episode, Rachel Wolcott and Lindsey Rogerson discuss the UK Financial Conduct Authority’s proposals to apply non-financial misconduct rules to an additional 37,000 regulated firms and lessons from the recent Upper Tribunal decision in the Jes Staley case. They begin by recapping the findings from the FCA’s survey of non-financial misconduct which was published last year as way of highlighting why the rule changes to the Code of Conduct (COCON) and Fit and Proper assessments is needed. They discuss why compliance and legal professional think guidance will help firms decide what “serious” bullying and harassment look like and most importantly how to deal with the individuals perpetrating such incidents. They also talk reasonable steps for managers who witness -- or are made aware that a member of their team is suspected of – non-financial misconduct. The conversation then moves onto consider the implications for financial firms’ senior executives and boards of the recent Upper Tribunal decision against Jes Staley, former CEO of Barclays. Links:July 2021 FCA/PRA joint discussion paper: Diversity and inclusion in the financial sector – working together to drive change https://www.fca.org.uk/publication/discussion/dp21-2.pdf September 2023 FCA consultation paper: Diversity and inclusion in the financial sector – working together to drive change https://www.fca.org.uk/publication/consultation/cp23-20.pdf March 2024 Treasury Committee Sexism in the City report expresses concern over D&I plans https://committees.parliament.uk/publications/43731/documents/217019/default/ October 2024 FCA survey of non-financial misconduct https://www.fca.org.uk/data/culture-non-financial-misconduct-survey-findings March 2025 FCA abandons D&I plans https://www.fca.org.uk/news/statements/update-fca-enforcement-transparency-proposals July 2025 Non-financial misconduct CP published CP25/18: Tackling non-financial misconduct in financial servicesJes Staley and Jeffrey Epstein: Evidence That Doomed Ex-Barclays CEO’s Career (paywall) Upper Tribunal Decision in Staley case: https://assets.publishing.service.gov.uk/media/685d21fec2633bd820a92a52/Staley_v_FCA_decision_for_release.pdf 

This week we’re bringing an episode featuring Ilia Shumanov, board member at Transparency International Russia in Exile and the co-founder of Arctida, a non-profit focused on challenges facing the Russian arctic. Ilia speaks with Rachel Wolcott, Compliance Corylated’s founding editor about their recent collaboration investigating the son of a Russian Duma deputy and alleged gangster who grew up outside Russia in the US and UK private schools. Boris Borisovich Ivanyuzhenkov is another wealthy, young Russian with elite connections. Despite his father Boris Viktorovich Ivanyuzhenkov being a high-ranking figure in the legendary Podolsk OCG, young Boris has traveled the world playing tennis and is the director of several property businesses in the US and Europe. He also happens to be best friends with Mikhail Fedotov, son of energy tycoon Viktor Fedotov.Ilia and Rachel unpack the case and talk about what it says about the challenges for financial crime investigators and journalists! LinksThe NepoPEP: Alleged Russian gangster’s son’s US property companyThe NepoPep: Sons of Duma deputy and UK Conservative party donor run German property businessesContacteditorial@corylated.com Transparency International Russia 

This week we’re bringing an episode featuring Ilia Shumanov, board member at Transparency International Russia in Exile and the co-founder of Arctida, a non-profit focused on challenges facing the Russian arctic. Ilia speaks with Rachel Wolcott, Compliance Corylated’s founding editor about the ‘Golden Youth’ series of articles examining one of the actors involved in multi-billion-pound crypto laundering scheme. Ilia and Rachel recently collaborated on an investigation into the Semen Kuksov case. Kuksov, a young wealthy Russian, was jailed in 2024 in the UK after pleaded guilty to laundering £12 million through his cash-to-crypto operation. Ilia and Rachel unpack the case and talk about what it says about Russian sanctions evasion and money laundering methods today.  Links First article: Golden Youth, the new face of Russian money laundering and sanctions evasion Second article: The privileged, privately educated Russian who ran a cash-to-crypto MLAAS for other wealthy Russians and drug traffickers Third article: Wealthy Gen Z Russian laundered money in luxury properties, claimed ADHD caused offending Metropolitan police: Money laundering gang who exploited Russia-Ukraine war jailed (press release)  Crown Prosecution service: Men jailed for laundering more than £12m of criminal cash (press release) Contact: editorial@corylated.com  

In this episode, Lindsey and Rachel cover the sentencing of UK art dealer for failing to report suspicion of terrorist financing when dealing with a sanctioned individual. Oghenochuko Ojiri, who was given two and a half years in prison, subscribed to an art market due diligence service, but did not heed its findings.  Mrs Justice Cheema-Grubb told Ojiri during sentencing: “These offences are so severe that only a custodial sentence can be justified. Working in a regulated sector brings responsibilities, but you closed your eyes to what you knew.” Listen in for further insights from the sentencing. Links:Jailed UK art dealer ignored due diligence platformʼs alert on Hezbollah financier Full sentencing remarks on Sky News Courts Compliance Corylated video: Follow the handbags, new reporting rules for high value dealers   UK Financial Intelligence Unit’s SARs report 2023/24  Money laundering risks in UK higher education report  Contact us: editorial@compliancecorylated.com  

In this episode Lindsey Rogerson and Rachel Wolcott discuss the UK Financial Conduct Authority’s updated version of its Enforcement Guide. They begin by recapping on the intentions behind proposals to change the “exceptional circumstance” test for disclosing if/when a financial services firm was under investigation. They discuss the entirely foreseeable backlash and justifiable industry concern about naming firms when time for FCA to complete investigations was running at an average of 42 months. The conversation then moves onto consider where the consultation landed on transparency and what if anything has really changed.  Rachel also shares some insight on the cost of prosecuting small scale insider dealing cases on the back of a response she received to a request under the Freedom of Information Act 2000.  And Lindsey considers whether a House of Lords amendment to the UK Employees Rights might succeed in where PS25/5 failed in encouraging whistleblowers to come forward.  Links: FCA spent over £300k on insider dealing duo who made £43k Over 50% of FCA investigations are public FCA policy statement 25/5: Our enforcement guide and greater transparency of enforcement investigations  House of Lords Financial Services Regulation Committee report: Naming and Shaming: How not to regulate  Recent FCA apologies to Collateral investors, FundingSecure customers, and Basset & Gold minibond investors for slowness in handling complaints about how these firms were authorised and supervised.  

UK financial services firms are still falling short when it comes to their vulnerable customers. The Financial Conduct Authority (FCA) explored the issue in its March review, highlighting that the financial services industry is still not doing enough. To unpack the challenge, Niece Prayoonrat, a reporter at Corylated, speaks to Howard Taylor, a director at PwC’s Risk and Compliance Transformation Consulting practice. Howard participated in the FCA’s panel launching its most recent work on vulnerability and has advocated for a needs-led and customer-focused approach to vulnerable customers. He also offers valuable insights as a wheelchair user. In this episode, Niece and Howard discuss how organisations and regulators can better serve those who are sometimes left behind. Howard addresses how product and business teams can design products with vulnerable customers in mind, whether a one-size-fits-all approach might actually be harmful, and the overarching vision from current government workstreams. Links:Banks fail vulnerable customers; most UK adults reluctant to disclose status UK elderly fraud victims lose £4,000 per scam, research says Smart data central to next evolution in banking services Delivering good outcomes for customers in vulnerable circumstances – good practice and areas for improvement (UK Financial Conduct Authority) Contact us editorial@corylated.com compliancecorylated.com

In this episode Lindsey Rogerson and Rachel Wolcott begin by discussing why the UK is such a hotbed for fraud and go onto consider the recent drop in authorised push payment (APP) fraud in the UK following the introduction of mandatory reimbursement in October 2024.  The conversation then moves onto the European Payments Services Directive (PSD3) and how it is being updated in an effort to clampdown on the use of virtual IBANs by fraudsters. The lack of user-friendliness of fraud warning lists issued by European and global regulators is then discussed alongside the Financial Conduct Authority's Register.  Rachel and Lindsey highlight instances where the Register has been part of the problem in amplifying the “halo” effect of an FCA authorisation before wrapping up the conversation with a look at how fraud is increasingly perpetrated by international criminal gangs and what the UK’s hotly anticipated UK Fraud Strategy might include.  We’re taking a break and will be back in June with more Corylated. In the meantime, please like, subscribe and leave a 5-star review! Thanks for listening!  Links: Payment Systems Regulator 2024 APP reimbursement data: APP fraud performance data | Payment Systems Regulator BBC Panorama episode on Blackmore Bond: https://www.bbc.co.uk/programmes/m001b7jh  UK could revoke trade and aid in fight against online fraud - Compliance Corylated UK elderly fraud victims lose £4,000 per scam, research says - Compliance Corylated UK lost $33.2bn to frauds and scams in 2024 - most in EU  Zelle mentions on Facebook ads ‘correlatedʼ to scams, Meta says   - Compliance Corylated PSR shares early findings from APP fraud repay scheme