ISSUE 37 inCOMPLIANCE - int-comp.org

1 Get SmartISSUE 37 YOUR MAGAZINE FROM THE INTERNATIONAL COMPLIANCE ASSOCIATIONinCOMPLIANCE Go with the a wider lensPeople, outcomes, principles where sold 3inCOMPLIANCE 3inCOMPLIANCE 312-13 November 2018 AmsterdamThe premier European conference for compliance, risk, and ethics officersTo Register, please go online or +1 (617) 570-8600 Powerful Insights. Pratical Ideas. Real you to our sponsors: CD-10874 ICA members save 200 at registration. CWE18 ICALisa Kristin Miller Head of Integrity Compliance OfficeWORLD BANK GROUPV entsislav Karadjov Vice ChairmanEUROPEAN DATA PROTECTION BOARDS egev Shani Chief Compliance OfficerNEOPHARMR obert Seibel Senior Compliance CounselABERCROMBIE & FITCHC hristine Uriarte Senior Legal Analyst, Anti-Corruption DivisionOECDK arina Litvack Board of Directors ENIE nhance your marketing efforts through event sponsorship and product promotion.

2 To learn more, please contact Doug Juene-mann at (617) 570-8610 or 19/4/2018 2:47:02 PMinCOMPLIANCE 3inCOMPLIANCE 3inCOMPLIANCE 3 Editorial BoardKathryn Cearns, Independent Consultant, Meng Chen, Commerzbank, Ghanty, Kemp Little LLP, Porter, Director, TPA (Consulting) Ltd, Salmond, Ernst & Young LLP, Symes, Compliance Recruitment, Waldren, Murray Waldren Consulting, ISSUE 37 Publisher: International Compliance James Design & Document Dorinda Gibbons & Sophy Queries: Dorinda President, International Compliance Association: Bill Membership Enquiries: Jo Qualification Enquiries: Debbie Enquiries Compliance Association CPD - 2 pointsAdvice to ReadersinCOMPLIANCE is published six times a year by the International Compliance Association.

3 Reproduction, copying, extraction, or redistribution by any means of the whole or part of this publication must not be undertaken without the written permission of the publishers. inCOMPLIANCE is distributed as a free member benefit to all members of the International Compliance are published in good faith without responsibility on the part of the publishers or authors for loss occasioned to any person acting or refraining from action as a result of any views expressed therein. Opinions expressed in this publication should not be regarded as the official view of the ICA or as the personal views of the Editorial Board members of inCOMPLIANCE .

4 All rights reserved in respect of all articles, drawings, photographs etc published in inCOMPLIANCE anywhere in the world. Reproduction or imitations of these are expressly forbidden without permission of the in EnglandWe live in a complex, interconnected world in which risks (and opportunities) appear to emerge with ever greater frequency. Related to this complexity are the incessant demands made on our time, with our attention crowded by growing volumes of information from an increasing (and increasingly unfiltered and/or unregulated; ) range of sources.

5 It is perhaps hardly surprising when individuals and organisations, struggling to operate in the face of such complexity, exchange shades of grey for black and white , and reduce complex decisions into binary choices (intentionally or otherwise). Paradoxically, it is this approach that may introduce the greatest risks of all. Witness, for example, the binary solutions offered by some parties to what they perceived as the threat posed by immigration ( build a wall! ; Brexit! ). Within the financial sphere a parallel may be found in the recent practice of wholesale de-risking ( ).

6 Rather than adopting fixed, binary positions on complex issues there is a need to develop and implement more flexible, fine-grained, multi-dimensional approaches to understanding and assessing risk (and opportunity). Compliance practitioners have much to offer both to their businesses and to society at large in this with complexityJames Thomas EditorinCOMPLIANCE 5inCOMPLIANCE 5inCOMPLIANCE 4inCOMPLIANCE 5 Contents3 Editor s commentRather than adopting fixed, binary positions on complex issues there is a need to develop and implement more flexible, fine-grained, multi-dimensional approaches to understanding and assessing risk (and opportunity)

7 , writes James Thomas6 ICA News A roundup of the latest news and events from the ICA8 Industry NewsA summary of recent developments affecting Financial Crime Prevention, GRC, AML and CDD professionals25 Compliance Recruitment David Jackman offers advice for those planning to recruit compliance staff, amidst the emergence of a new compliance 10 ICA Singapore Award Ceremony12 Join the conversationJames Thomas previews the inaugural ICA Asia Pacific Conference14 Get smartVivek Padmanabhan outlines the new frontier of smart Compliance: Holistic Cognitive Compliance18 Go with the Berezansky considers the paradigm shift occurring at the nexus of people, money and data, and its implications for regulation20 Get aheadZo Newman outlines the challenges of and approaches to anticipating, detecting, and responding to global risksREGULAR FEATURESIN THIS ISSUEPAGE 14 PAGE 22 PAGE 18inCOMPLIANCE 5inCOMPLIANCE 5inCOMPLIANCE 522 Through a Wider LensEmily Arries considers the practice and implications of de-risking28 People, outcomes.

8 PrinciplesPaul Asare-Archer highlights the importance of people, outcomes and principles in compliance 31 Data breaches in the Golden Age Within an environment of increasing cybercriminal activity, the new civil claims that data subjects can bring for data breaches under GDPR create significant financial exposure for financial services companies. Ann Henry considers how to hedge this risk34 Think inside the boxSimon Gray explores the what, where, when, how, why and who of regulatory sandboxes38 Towards transparencySvetlana Snezhko considers trends around the disclosure of compliance information within companies public reports41 The Big Compliance ConversationThe ICA, in collaboration with Broadgate, considers whether Manchester is the new LondonHave you thought about writing an article for inCOMPLIANCE ?

9 Writing an article is a great opportunity to raise your profile within ICA and present a topic of relevance to your fellow members. Writing an article on anti-money laundering, compliance, financial crime or associated disciplines will also earn you valuable CPD!Visit and download our document on Article writing tips and Blogging Best Practice to enhance your skills in this area and learn about structure, themes and writing note: you don t have to be an ICA Member to register your interest in submitting. If you are interested in writing an article for inCOMPLIANCE , email us at.

10 And remember to include your full name and your topic of 31 PAGE 34inCOMPLIANCE 7 Truly internationalICA Qualification Series Launch in CambodiaThis new launch is part of ICA s geographic expansion into the APAC region and signifies an exciting period of growth, as well as the growing demand for skilled compliance professionals in the ICA International Advanced Certificate in Anti Money Laundering (AML) will ensure that compliance professionals have the required understanding and tools to meet ongoing regulatory compliance challenges. Firms who have enrolled on the programme will be able to utilise their Staff Development qualifications are offered through the International Compliance Training Academy (ICTA), the Association of Banks in Cambodia (ABC) and the Institute of Banking and Finance Cambodia (IBF).