Compliance Officers Playbook

Become a Paid Subscriber: <a href="https://creators.spotify.com/pod/show/cos-playbook/subscribe" target="_blank">https://creators.spotify.com/pod/show/cos-playbook/subscribe</a> Compliance Officers Playbook is your trusted companion in the world of compliance. Whether you’re a new to Compliance or a Junior Professional aiming to fast-track your journey to becoming a successful Chief/Compliance Officer, or you are a new or a seasoned Chief/Compliance Officer looking to sharpen your skills and broaden your expertise, this podcast delivers actionable insights, industry best practices, and thought-provoking discussions to elevate your career. Join us as we uncover the strategies and tools that empower compliance professionals to lead with confidence and integrity.

Freemium - Unpacking Morgan Stanley's €101 Million Dividend Tax Penalty

In this episode, we unpack the major enforcement action taken against Morgan Stanley after Dutch authorities uncovered its role in coordinated tax evasion schemes. Following extensive audits and criminal investigations, regulators issued a €101 million fine—the maximum possible—after determining that the firm used complex trading and derivative strategies to exploit dividend withholding tax rules.We break down how a Dutch subsidiary was positioned as the apparent dividend recipient while the real economic benefits were funneled to foreign institutions that weren’t eligible for Dutch tax credits. The case reveals the intricate architecture behind these cross-border dividend schemes and highlights why prosecutors viewed the conduct as a deliberate misuse of the tax system.Finally, we examine the broader implications for international dividend trading models and what this landmark sanction means for financial institutions operating across jurisdictions. Tune in for a clear, in-depth look at a case reshaping global tax-compliance expectations.

12-02
04:44

Quiet Failures in Compliance: How Everyday Oversights Lead to Major Crises

In this episode, we explore the ideas behind “Compliance: Quiet Failure, Safe Guardrails,” a compelling look at how organisational breakdowns rarely result from one dramatic event. Instead, they stem from small, repeated oversights—missed documentation, ignored red flags, and routine shortcuts—that quietly stack up until they explode into full-blown regulatory failures or reputational crises.We discuss why strong compliance isn’t built on emergency responses but on consistent daily behaviours: clear processes, leadership that prioritises risk mitigation, and a culture that understands compliance as a strategic safety mechanism. Rather than a brake on growth, the text argues, compliance is an essential guardrail that enables companies to scale safely and sustainably.Tune in to learn why the quietest failures are often the most dangerous—and how organisations can prevent them.

12-02
13:26

Freemium - Why Coinbase’s €21.5M Fine Signals a New Era of EU Crypto Compliance Under AMLA

In this episode, we break down the landmark €21.5 million fine issued to Coinbase Europe Ltd by the Central Bank of Ireland—a ruling widely seen as a preview of what’s to come under the EU’s new Anti-Money Laundering Authority (AMLA).We explore how systematic coding errors left Coinbase’s transaction-monitoring system ineffective for nearly four years, allowing more than 30 million transactions to go improperly screened. Regulators made it clear: technical failures aren’t treated as mere glitches—they’re serious compliance breaches, even if companies later conduct back-reviews to catch missed red flags.The message to the crypto industry is unmistakable. Virtual Asset Service Providers must now operate with the same real-time governance and bank-grade controls expected of traditional financial institutions. As AMLA prepares to centralise and tighten anti-money laundering enforcement across the EU, this case sets a powerful new benchmark. Tune in to understand how this ruling could redefine compliance expectations for crypto players across Europe.

12-02
04:30

Freemium - Digital Compliance: GDPR Enforcement and AI Convergence

In this episode, we unpack the increasingly complex landscape of the EU’s digital regulatory regime—one that continues to evolve around the foundations set by the General Data Protection Regulation (GDPR). Drawing on recent analyses, we explore how regulators are sharpening their enforcement approach, applying strict criteria that can lead to fines of up to four percent of a company’s global turnover.We look at real-world trends, including record penalties from Spain’s data protection authority, which signal a shift toward targeting systemic weaknesses in data security, governance, and risk management. From there, we examine how the EU’s new AI Act is creating fresh tension within the regulatory ecosystem—particularly where obligations for risk assessments, oversight bodies, and documentation overlap with long-standing GDPR requirements.Finally, we break down the practical guidance organizations must follow for international data transfers, including the need for robust safeguards and thorough transfer risk assessments to stay compliant. If you want a clear picture of where EU digital regulation is heading—and what it means for businesses navigating it—this episode offers a concise, informed briefing.

12-01
06:55

Wise Unlocks South African Payments Gateway

In this episode, we dive into Wise’s major move into the African market, starting with its newly launched operations in South Africa. After securing conditional approval from the South African Reserve Bank to operate as a regulated foreign-exchange dealer, the London-based fintech is taking a significant step toward transforming one of the world’s most important remittance corridors.We break down how Wise plans to deliver low-cost, real-time international payments to personal customers in its initial rollout—advancing the G20’s goal of faster, cheaper global transfers by 2027. You’ll also hear why Wise executives are calling this a milestone in reducing FX costs, and how UK Prime Minister Keir Starmer has publicly welcomed the move as a boost to UK–South Africa ties.If you want to understand what this expansion means for cross-border finance in Africa and the future of global remittances, this episode has you covered.

12-01
10:59

Australia's $82 Billion Organized Crime Bill, 2023–24

In this episode, we break down the Australian Institute of Criminology’s latest statistical report on the true economic toll of serious and organised crime in Australia during the 2023–24 financial year. The headline figure is staggering: an estimated upper cost of $82.3 billion, a sum that accounts for a significant slice of the nation’s GDP.We explore how this massive total is calculated—combining direct criminal losses with the indirect costs of prevention, enforcement, and response across both public and private sectors. From illicit drug markets and sophisticated financial crime to environmental offences, cybercrime, and the rapidly growing illicit tobacco trade, the report reveals just how widespread and costly organised crime has become.Finally, we unpack why the authors believe even these enormous figures are conservative, and what this means for policymakers, industry, and communities trying to curb the influence of organised criminal networks. Tune in for a clear, compelling look at the hidden economic drain shaping Australia’s security and economy.

11-30
29:08

Freemium - Offshore Secrecy: Assessing UK Overseas Territory Transparency

In this episode, we unpack Transparency International UK’s 2025 assessment of how the UK’s Overseas Territories are progressing—or failing to progress—on creating accessible registers of beneficial ownership. These registers are meant to shine a light on who really owns companies, a crucial step in fighting global illicit finance. But as the report reveals, the reality is far more complicated.We explore how opaque corporate structures in jurisdictions like the British Virgin Islands have enabled massive corruption and money-laundering schemes, and why the Overseas Territories’ shift from fully public registers to more restrictive “Legitimate Interest Access Registers” (LIARBOs) represents a major setback for transparency. You’ll hear which territories scored poorly due to slow implementation, limited access, and processes that could even tip off criminals—and why Montserrat stands out as the lone success story with a completely public, free-to-use register.Finally, we look at the report’s call for the UK government to step in, apply real pressure, and even consider constitutional measures to ensure these territories live up to their commitments. If you want to understand the global stakes of beneficial ownership transparency, this episode gives you the full picture.

11-30
05:04

Freemium - PSD3 and PSR: Securing the Future of EU Payments

In this episode, we break down the major political agreement just reached by EU lawmakers on two transformative pieces of legislation: the Payment Services Directive 3 (PSD3) and the new Payment Services Regulation (PSR). Together, these measures set the stage for a modernized, fairer, and more transparent financial ecosystem across Europe.We explore how the deal aims to crack down on fraud, introduce full reimbursement for victims of impersonation scams, and hold payment providers accountable for transfers sent to mismatched account details. You’ll also hear how the regulations strengthen consumer access to cash, protect open-banking innovators from discriminatory bank practices, and require crystal-clear transparency on fees and exchange-rate margins before any payment is made.If you want to understand how these upcoming changes will shape the way Europeans pay, bank, and protect their money, this episode breaks it all down in plain language. Tune in!

11-30
05:33

Freemium - FCA Regulatory Approach to Cryptoassets and Stablecoins.

In this episode, we explore the UK Financial Conduct Authority’s evolving approach to crypto regulation, drawing on key excerpts from the FCA’s mandate and a keynote speech by Executive Director David Geale.We break down the FCA’s vision for building a trusted, competitive, and innovative market for cryptoassets and stablecoins—one that doesn’t simply copy traditional finance rules but instead reflects the unique challenges of decentralised technology. You’ll hear how the regulator is shaping a bespoke, proportionate framework, supported by active industry consultations and a new stablecoin-focused cohort within the FCA’s Regulatory Sandbox.We also discuss what’s coming for crypto firms: mandatory authorisation, high standards, and rigorous expectations designed to ensure strong consumer protections once the new regime goes live. And finally, we look at the UK’s commitment to working alongside international partners to influence and align global standards for digital asset oversight.If you want clarity on where UK crypto regulation is headed and what it means for the industry, this episode is your guide.

11-27
05:06

Freemium - The Cost of Postponing Compliance: CSSF fines AllianzGI Luxembourg for AML/CFT failures

In this episode, we examine the story behind a major regulatory enforcement action in Luxembourg’s financial sector: the €283,000 administrative fine imposed on Allianz Global Investors’ Luxembourg branch for persistent anti-money laundering (AML) and counter-terrorist financing (CFT) failures.We unpack the findings of a 2018 CSSF inspection that uncovered serious gaps—including the omission of more than 1,000 investors from the branch’s AML/CFT risk analysis and weak due-diligence documentation for politically exposed persons (PEPs). Although AllianzGI maintains that the issues were procedural and have since been fully corrected, the case highlights a broader industry trend in which firms delay critical compliance work to focus on short-term business priorities.We also discuss the timeline: the penalty issued in 2022 and upheld in court in 2025—evidence of the regulator’s determination to confront systemic weaknesses in financial controls.Tune in for a clear look at what this case means for compliance culture, supervisory expectations, and the financial industry’s ongoing struggle to balance growth with robust risk management.Full Episode on Apple Podcast

11-26
05:35

Freemium - New Zealand No Longer Requires Address Verification for Customer Due Diligence.

In this episode, we break down a sweeping Statutes Amendment Bill—an omnibus legislative package crafted to update and refine large sections of the existing legal framework. Spanning 42 separate parts, the Bill reaches across a wide array of principal Acts, making it one of the most comprehensive housekeeping efforts in recent legislative cycles.We walk through the key areas of reform, from environmental and conservation laws to updates in anti-money laundering and counter-terrorism financing rules. You’ll also hear about notable changes to the Defence Act 1990, important adjustments to personal data protections under the Privacy Act 2020, and targeted revisions to land and criminal justice legislation.This episode serves as your guided tour through the Bill’s catalogue of amendments—what’s being inserted, updated, or replaced—and why these technical but essential changes matter for maintaining a coherent, modern, and effective statute book.

11-26
04:12

Freemium - Navigating Risk: From Certainty to Resilience

In this episode, we explore the complex and often uncomfortable world of risk management, especially for those with a perfectionist mindset. Unlike compliance, which operates with clear rules and definitive answers, risk management lives in the grey areas of uncertainty. We discuss why business growth actually depends on embracing this uncertainty rather than trying to eliminate it. The episode highlights how effective risk management is about building resilience—making informed decisions with incomplete information while staying open to opportunities that emerge from the unknown.

09-13
04:52

Freemium - Swiss AML Debate: Credibility vs. Competitiveness

In this episode, we dive into Switzerland’s heated debate over proposed anti-money laundering (AML) reforms driven by FATF recommendations. Lawmakers are pushing back against stricter rules for lawyers, advisers, and trusts, arguing that excessive regulation could weaken Switzerland’s financial competitiveness and autonomy. This resistance comes despite warnings from the Federal Department of Finance that failing to act could harm the country’s international credibility. We explore how these political tensions have led to key exemptions, including non-profit organisations and certain trust structures being left out of a new transparency register. The debate is unfolding at a critical time, as global competition intensifies—particularly with Hong Kong expected to overtake Switzerland as the world’s leading cross-border wealth management hub by 2025.

09-13
06:03

Georgia’s Defense Minister Charged with Abuse and Money Laundering

In this episode, we examine the corruption and money laundering case involving Georgia’s former Defense Minister, Juansher Burchuladze. According to investigators, Burchuladze abused his authority in 2023 by orchestrating a non-competitive procurement of medical equipment, inflating prices for personal and family gain, and causing more than 1.3 million GEL in losses to the Ministry of Defense. To conceal these illicit funds, he and his wife allegedly purchased property in Spain in 2025 using unsubstantiated income, later creating a fake real estate agreement in Tskneti to disguise the money’s origin. Investigators also discovered that Burchuladze failed to disclose the Spanish property in his asset declaration, effectively laundering 1.5 million GEL. Facing charges that carry a potential 12-year prison sentence, the Prosecutor’s Office is seeking his pre-trial detention as the investigation continues.

09-13
11:53

Freemium - Bunq Fined €2.6 Million for AML Failures

In this episode, we cover the recent case of Dutch neobank Bunq, which has been fined €2.6 million by the Dutch central bank for repeated failures in its anti-money laundering (AML) controls. Despite prior warnings and interventions, Bunq reportedly fell short in investigating suspicious transactions and applying adequate scrutiny to certain customers across multiple cases. This enforcement action reflects a broader wave of heightened regulatory scrutiny affecting both traditional banks and fintechs in the Netherlands. While Bunq is challenging the fine and cites ongoing technological improvements, the case highlights the difficult balance digital-first banks must strike between rapid innovation and strict compliance standards. With the outcome of Bunq’s objection still pending, this serves as a strong reminder to the fintech industry: robust AML systems are not optional—they’re essential.

09-07
07:22

Freemium - Abramovich's Billions: Corruption and Money Laundering Investigation in Jersey

In this episode, we examine the ongoing criminal investigation into Roman Abramovich, former owner of Chelsea FC, led by Jersey authorities. The probe focuses on allegations of corruption and money laundering tied to the origins of Abramovich’s wealth, particularly his multibillion-dollar sale of oil and gas giant Sibneft in 2005. Swiss courts have ordered the release of key banking documents to assist investigators, shedding light on the complex movement of funds across offshore entities and accounts with limited economic transparency. The investigation also looks into potential sanctions breaches related to asset transfers around the time Abramovich was sanctioned following Russia’s invasion of Ukraine. While Abramovich denies any wrongdoing, Swiss judges have determined there is sufficient evidence to continue the inquiry, marking a significant development in the international fight against financial crime.

09-07
05:28

Freemium - Europe's New Anti-Money Laundering Authority (AMLA): A New Era

In this episode, we introduce the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), the European Union’s new decentralised agency designed to harmonise and strengthen AML/CFT supervision across member states. We explore AMLA’s core functions, including direct oversight of high-risk financial entities, coordination of national financial intelligence units (FIUs), and the development of common regulatory standards. The discussion highlights how AMLA seeks to close gaps and inconsistencies in national supervision, ultimately boosting the EU’s effectiveness in fighting financial crime. We also cover its establishment timeline and share an important warning: AMLA will never contact individuals directly for financial information or issue personal fines, helping citizens avoid scams while the agency takes shape.

08-18
05:50

Freemium - Dormant Accounts: Risks, Management, and Best Practices

In this episode, we unpack the multifaceted world of dormant accounts—what they are, the risks they pose, and how they’re managed across different contexts. We explore best practices for identifying and securing inactive accounts, from fraud prevention to working with executors, while addressing potential risks like identity theft, unexpected fees, and credit score impacts. We highlight the UK’s Dormant Assets Scheme, a voluntary initiative aimed at reuniting people with their forgotten financial assets or redirecting them to social and environmental causes. The episode also examines the role of dormant accounts in fraud detection, with sudden reactivation or large transactions serving as potential red flags, and stresses the need for long-term monitoring strategies. Finally, we discuss the critical importance of identity verification in safeguarding dormant accounts, protecting savings, and ensuring access to compensation schemes.

08-13
04:59

FCA Convicts Daniel Pugh for £1.3M Ponzi Scheme

In this episode, we cover a recent enforcement case from the UK’s Financial Conduct Authority (FCA) involving the conviction of Daniel Pugh, who ran the £1.3 million Imperial Investment Fund—a Ponzi scheme that defrauded 238 investors. Largely promoted through Facebook, the scheme lured victims with promises of unrealistic daily, weekly, and annual returns. We discuss the charges brought against Pugh, including conspiracy to defraud and breaches of the Financial Services and Markets Act 2000 for unauthorised regulated activity and unlawful promotions. The FCA has reaffirmed its commitment to tackling financial crime and will now pursue confiscation proceedings to recover the illicit profits from this case.

08-13
08:06

West Virginia Man Pleads Guilty to Money Laundering

The U.S. Department of Justice press release details the case of James E. Monroe Jr., who pleaded guilty to money laundering in the Southern District of West Virginia. Monroe concealed assets during bankruptcy proceedings, including a sports card collection and the sale of his house. He faces a potential 20-year prison sentence and significant fines. The FBI and the U.S. Trustee Program investigated the case, and the U.S. Attorney's Office is prosecuting. The press release provides contact information for the Southern District of West Virginia U.S. Attorney's offices and resources for staying connected with the department.Love our content? Unlock exclusive episodes and dive deeper with us! Become a paid subscriber today and get full access to all premium episodes—packed with insights, stories, and value you won’t find anywhere else. Support the show and elevate your experience.Subscribe now!

02-09
06:47

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