Fraud and financial crime – Keeping up with global sanctions to ensure enforcement across institutions


By Oliver Beckmann, Vice President / Head of Business Advisory Sanctions, Group Compliance, Commerzbank

Interview ahead of the 2nd Annual Fraud and Financial Crime Europe Summit, taking place 2-3 April in London

Oliver Beckmann joined Commerzbank AG in 2017 as Head of Business Advisory Sanctions / Group Compliance Frankfurt, Germany. Oliver and his team are responsible for all customer related topics connected to Sanctions and Embargos and support all business units of Commerzbank worldwide in mastering the world of Sanctions and Embargoes. Oliver is an in-house lawyer and accredited German lawyer and has more than 6 years of compliance and banking experience.

Oliver started his career with HypoVereinsbank/UniCredit Group, Munich Germany. He holds a law degree (1st State Exam) from the University of Regensburg and completed his legal clerkship (2nd State Exam) at the Nürnberg Higher Regional Court/Germany.

At university he specialized in Commercial, Corporate and Tax Law while he used his specialization later on in becoming a subject matter expert on compliance in regard to AML, Financial Sanctions and Embargos related questions, especially in the field of Investment Banking and Trade Finance.

What, for you, are the benefits of attending a conference like the Fraud and Financial Crime Europe Summit and what can attendees expect to learn from your session?

It is of great value to have an exchange with colleagues and experts to share best practices on financial crime, newly developed or recognized patterns in detecting and combating financial crime and to learn in general from different setups, ides, risk perspectives and technologies that help to cover risks in the area of financial crime.

In your opinion, what could be the next steps in sanctions on Russia?

There is always the need to differentiate between the EU and the US perspective. The EU might adopt some of the Oligarch Sanctions that have been previously initiated by the USA in April 2014. It is likely the EU would upfront check what impact that would have on European companies involved in Russia trade. Any EU Sanctions would be connected to the developments in Crimea and the eastern part of Ukraine. Currently the outlook for easing of the situation are not to good and the EU will strictly stick to the results or non-results of the Minsk treaty.

From the US perspective it is more likely that there will be more sanctions coming just for the fact that the Congress wants the executive branch to step up the sanctions on Russia. As Donald Trump gets more push back on internal politics he might use more sanctions on Russia to shift the focus away from internal US politics.

Additional sanctions are likely to be aimed at more people that are already on the Oligarch lists but not yet subject to OFAC sanctions. There might be some more directed sanctions on the environment around North Stream II, more likely to affect specific companies that provide direct services related to the construction of the pipeline.

How different legislations impact financial firms’ work on sanctions?

Basically there are 3 big players that set the rules: The USA, the UN and the EU.

What makes it difficult to cover US and EU sanctions on a global scale is the disruption caused by data protection and banking secrecy laws that impact holistic screening and monitoring of sanctions risks.

Basically any legislation that impacts end to end processes that are originally designed to identify sanctions risks and hinder a necessary information sharing cross border will always hinder an effective fight against financial crime.

What are the risks of secondary sanctions for Iran?

If you or your customer is dependent on the access to the US-financial system, on US-goods or your sales are connected to the US secondary sanctions should be treated like they were directly applicable. Simple for the fact that you don’t want to lose you “market access”. And everyone else should be aware even if he has no dependency on “US-market access” should check if his customers and suppliers are active or dependent on the “US-market access”. Why? You want to be in business with them in the future and your customers will likely want to reduce any risks that might have an impact on their own access to the US-markets and if this is at risk if they are doing business with parties that are actively “ignoring” US-sanctions.

It is not the risk of an enforcement actions, it is more the risk to lose your own customer base if you would be listed for Iran Sanctions Evasion activities. That will hurt the most.

How do you see the impact of Fraud and Financial Crime evolving over the next 6-12 months?

We will likely see a spike of additional negative news in the context of financial crime and enforcement actions of regulators around the world. The better the information flow becomes the better the identification rate of financial crime. On the contrary new technologies and trends like crypto currencies, additional payment methods, etc. will make it harder to keep up the fight against financial crime as existing screening and monitoring systems will have to be tuned and adopted to those new technologies and patterns. It will get more complex, that’s for sure.

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