Author: Michal Kaczmarski

VII Pillar DOJ & SEC Program for safe navigation towards diligent prevention of fraud, corruption and other damages to business organizations deriving from misconduct

All business organizations may be held liable for criminal misconduct of their agents, e.g. staff, subcontractors or joint-venture partners. In order to avoid this liability the businesses need to prove diligence in selection, supervision over agents and controls held withing the organization, i.e. the controls landscape and their robustness. There is no one fits all… Continue reading VII Pillar DOJ & SEC Program for safe navigation towards diligent prevention of fraud, corruption and other damages to business organizations deriving from misconduct

The „Six Principles Guidance” by the UK Ministry of Justice

Contains public sector information licensed under the Open UK Government Licence v3.0. Version OGW 1, Published January 2020 © Crown Copyright, 2020. In 2011, the UK Ministry of Justice published its first statutory guidance under the UK Bribery Act 2010 to help organisations understand the sorts of procedure they can put in place to prevent… Continue reading The „Six Principles Guidance” by the UK Ministry of Justice

AML/CFT Transaction Monitoring – introduction to the basic concept

AML/CFT transaction monitoring is equally if not more challenging than Risk-based Approach towards KYC procedures. Of course all depends on the business context, volume of clients, volume of transactions, technology available to support the business processes and controls embedded in them, and so on, and so far. In this blog entry I am going to… Continue reading AML/CFT Transaction Monitoring – introduction to the basic concept

Ongoing Risk-based Customer Due Diligence

Sometimes we may wonder, what Ongoing Risk-Based Customer Due Diligence means. The easiest answer is that we need to constantly monitor our relationship with a customer bearing in mind the diagnosed risks embedded in this relationship. When we translate this model into practice we could consider three variables: static customer information collected, verified and documented… Continue reading Ongoing Risk-based Customer Due Diligence

The threat of counterfeit medicines in a short summary

The recent “Intellectual Property Crime Threat Assessment 2022” by European Union Intellectual Property Office (EUIPO) and Europol proves that: “The distribution and use of counterfeit medicines and medical supplies can cause significant direct harm to the health of victims” “Some fake medicines contain less/no active ingredients compared to the genuine products” “In some other cases,… Continue reading The threat of counterfeit medicines in a short summary

Risk-based approach in client/vendor risk scoring at on-boarding

Client/vendor risk scoring is generally a dynamic process that gets initiated at customer on-boarding and continues over the lifecycle of customer relationship. However, I assumed that for the sake of simplification the example given in this article focus on the on-boarding risk scoring, which after initiation of the business relationship that often fluctuates while the… Continue reading Risk-based approach in client/vendor risk scoring at on-boarding

Risk assessment factors in customer due diligence

Many may wonder where to start when engaging with a robust customer’s risk assessment and measuring one’s own risk exposure. The below example may help to understand the engineering of the process. Its is good to start from the scratch and draw a mind map. The mind map to be aimed at visualising the risk… Continue reading Risk assessment factors in customer due diligence

Debunking common myths on the criminal use of cryptocurrencies

Based on the Europol’s report “Cryptocurrencies: tracing the evolution of criminal finances” [(Europol (2021), Europol Spotlight Report series, Publications Office of the European Union, Luxembourg] Nowadays, cryptocurrencies are not the major mean of settlement of criminal deals “The use of cryptocurrency as part of criminal schemes is increasing, and the uptake of this payment medium… Continue reading Debunking common myths on the criminal use of cryptocurrencies

Know Your Customer and Know Your Vendor

Engagement with a new business partner brings hope for successful cooperation, increased revenue or reduced costs. However, one cannot forget that each new business relationship is also associated with a risk that may damage the business or the relationship if not properly managed. This article is aimed at providing a few practical tips on risk… Continue reading Know Your Customer and Know Your Vendor