The development of government support for compliance managers training in Russian Federation

The article reflects ?n the problems of government support for the training of compliance officers in the Russian Federation. This problem became more acute in connection with the consolidation in clause 3 of the Order of the Government of the Russian Federation No. 1697-r of August 16, 2018, the requirement to create internal systems under state and municipal authorities, ensuring that their activities comply with the requirements of antimonopoly legislation. The lack of theoretical and practical knowledge of civil servants in this area (the area of compliance) determines the relevance of the problem under consideration. This mostly concerned t? yesterday's students who are unable to provide payment ?f additional education in this area due to lack of financial resources. This entails the lack of qualifications of civil servants in the area of compliance and the ineffectiveness of compliance programs they are running. In the course of the study, we concluded that it is necessary to adopt in Russia a Scandinavian approach of government support for the training of labor resources at the expenses of the national budget and taking into account the real need for labor resources in regions and municipalities.

Naloxone Buyers Club: Overlooked Critical Public Health Infrastructure for Preventing Overdose Deaths

Background Community-based naloxone distribution is an evidence-based pillar of overdose prevention. Since 2012, the naloxone Buyers Club facilitated purchase of low-cost naloxone by harm reduction and syringe service programs, the primary conduits for reaching people who use drugs. This innovative purchasing and mutual aid network has not been previously described. Methods We analyzed transactional records of naloxone orders (2017-2020, n=965), a survey of current Buyers Club members (2020, n=104), and mutual aid requests (2021, n=86). Results Between 2017 and 2020, annual orders for naloxone increased 2.6-fold. 114 unique harm reduction programs from 40 states placed orders for 3,714,110 vials of 0.4 mg/mL generic naloxone through the Buyers Club. States with most orders were: Arizona (600,000 vials), Illinois (576,800), Minnesota (347,450), California (317,200), North Carolina (315,040). Among programs that ordered naloxone in 2020, 52% (n=32) received no federal funding and ordered half as much as funded programs. During the 2021 shortage, mutual aid redistribution was common, with 80% participating as either a donor or recipient. Among 59 mutual aid requestors, 59% (n=35) were willing to accept expired naloxone; the clear preference was for generic injectable naloxone, 95% (n=56). Conclusions The naloxone Buyers Club is a critical element of overdose prevention infrastructure. Yet, barriers from corporate compliance officers and federal prescription-only status impede access. These barriers can be reduced by FDA removing the prescription requirement for naloxone and government funding for harm reduction programs.

The Effectiveness of Anti-Money Laundering / Counter Financing of Terrorism Requirements in Fund Management Companies

Anti-Money Laundering / Counter Financing of Terrorism (AML/CFT) broadly encompasses regulatory requirements, acts and guidelines designed to curtail the practice of generating funds through unlawful or criminal activities. Several infringement notices were issued to market intermediaries due to provision breaches of the guidelines. Although policies and procedures have been tightened up to the level of satisfaction, assessing the effectiveness of AML/CFT legislation is still necessary. The main aim of the study is to examine the independent variables, namely competency level of compliance team members, regulatory compliance and quality of AML/CFT framework that influence the effectiveness of AML/CFTrequirements of the compliance officers that are working in FMCs in Malaysia. The Expectancy Theory has been applied to form the framework and to develop the hypotheses. Three hypotheses were developed and tested using the data from 70 samples of FMC's in Malaysia. The result of the study showed that there were significant relationships between the factors analysed in this study. This study will help the financial institutions especially the Fund Management Companies (FMCs) in understanding the factors that influence the effectiveness of AML/CFT requirements and taking necessary action to enhance their internal AML/CFT process and its compliance with the regulations. This would help the FMCs to have effective control of AML/CFT during the on-boarding and ongoing monitoring process.

“Cyber-laundering”: the change of money laundering in the digital age

Purpose This study aims to illustrate and determine how illegally obtained funds are laundered through online platforms and companies in different economic sectors in the digital age. Design/methodology/approach A qualitative analysis approach using purpose sampling methods, including 21 semi-structured interviews with prevention experts, compliance officers and convicted cybercriminals, resulted in the determination of concrete money-laundering methods involving the employment of online platforms provided by companies and institutions in different economic sectors. Findings The current study focuses on various companies in different economic segments that mitigate cyber laundering and the anti-money laundering measures that can be adopted. Therefore, this paper provides a detailed discussion and analysis on how money launderers avoid being detected. Both preventive and criminal perspectives are taken into consideration. Originality/value By identifying the gaps in the current anti-money-laundering mechanisms, it will provide compliance officers, legislators and law enforcement agencies with an in-depth insight into how cyber laundering operates in various economic sectors.

AML/CFT Approaches to Tax Evasion in Payment Institutions

This article focuses on the issue of tax evasion and approach of compliance officers in payment institutions thereto. As tax evasion represents a phenomenon that remains attractive globally and certain percentage of economic activities will still remain connected to such illegal acting, it’s necessary that attention will be paid to it. The primary aim of this article is to identify and define effective methods of compliance officers or departments in relation to their clients or their transactions where certain elements or aspects of tax evasion activities can be detected, in particular based on the obligations vested in national acts, covered by the Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU (hereinafter referred to only as the “AML Directive”). Hypothesis of this article will test the statement that compliance department applies adequate methodology and properly worded questions may differentiate between clients that are putting their efforts into money laundering, in particular tax evasion, and clients with legal intentions. First part of this article will describe existing legal framework covering the area of money laundering where the method of analysis, synthesis and descriptive method will be applied. Second part of this article focuses on respective approaches to different tax evasion efforts with the main methods of deduction, synthesis and empirical research. Certain element of comparative analysis will be applied as well. Weakness of this topic is the insufficiency of expert literature for this area when majority of sources come mainly from the publishing of international organisations and partially from the monographies of different authors covering this area only in a form of a side topic. Based on this fact, this work is mostly based on sources from international organisations as from monographies.

The Shariah Audit Framework from Practitioners’ Perspective: A Mirage or Fact?

The positive development of Islamic financial system nowadays leads to the growth of products and services offered by Islamic financial institutions. However, some of them may have overlooked certain aspects that could affect Shariah-compliancy of the products and services. The occurrence of Shariah non-compliance risk may would adversely affect the reputation of Islamic finance and the confidence of market participants among depositors and investors. This scenario calls for a systematic check-and-balance functions within the institution. Shariah auditor being one of the components of Shariah governance plays an important role in ensuring the effectiveness of internal control system for Shariah compliance. Prior research reveals that the standard Shariah audit framework has not been developed yet; thus, the present practice is carried out by the internal institutional effort which heavily relies on the conventional audit system. The aim of this study is to explore the relevancy of Shariah audit framework from the eyes of practitioners of various Islamic financial institutions; whether it is a new innovative discipline or merely replicating the conventional audit structure. Ten semi-structured interviews were conducted involving selected auditors, Shariah compliance officers and Shariah committee members. Thematic analyses were adopted to analyze the data. It can be deduced that there is a need for a specific Shariah audit framework as a benchmark but with certain requirements and limitations. This study may provide relevant guidelines especially for policymaker in developing a standardized specific framework for Shariah audit.

The potential negative impact of the misuse of Transparency International’s corruption index by the financial services industry

Purpose This paper aims to raise awareness of the potential misuse of Transparency International’s Corruption Perception Index (CPI) within the financial services industry and outline the potential negative impact this may have on society in certain developing countries. Design/methodology/approach This piece of research adopted a mix-method approach across three strands; an online line anonymous survey, consisting of 24 questions, face to face interviews with 10 anti-bribery and corruption compliance officers and three focus group, one in Hong Kong, India and Mexico. Findings The results of the research have evidenced that there is a lack of understanding of the methodology used to compile the CPI within the financial services industry and there is a potential adverse impact if misused. Research limitations/implications A potential limitation was the fact that the survey was written in English yet was distributed to some countries where English was not the respondents’ first language. As such, it was accepted that there may have been context challenges or a misunderstanding of what the question asked. Practical implications By raising awareness of the methodology of the CPI and the advantages and disadvantages of its use, it will enable the financial service industry to better understand the implications of using such an index and the impacts of its misuse. Social implications This research highlights that through the potential misuse and lack of understanding of the CPI by the financial services industry this may have an adverse financial, growth and development impact on societies in low ranked countries. Originality/value This paper draws on a sub-set of results from a wider piece of research that was undertaken for a Professional Doctorate. This research combined academic knowledge with practitioner research skills, providing an original contribution to knowledge surrounding corruption from a more targeted focal point, particularly with input from anti-bribery and corruption compliance officers in the financial service industry.

Money laundering via underground currency exchange networks

Purpose This paper aims to demonstrate how illicit funds are being laundered through underground currency exchange networks. Design/methodology/approach Sixty interviews with money launderers and compliance officers were conducted to identify methods relevant to current money laundering issues. Further, a quantitative survey of 200 compliance officers was administered. Findings The currency exchange method is highly suitable for money launderers with access to a criminal network. It may be used for placement or pre-placement. Evidently, the vast majority of compliance officers fail to recognize the utilization of this method in their daily business. Research limitations/implications Implications are based on the statements of 60 interviewees, comprising both alleged money launderers and compliance officers. Practical implications The study identified gaps in anti-money laundering mechanisms. The documentation of said inconsistencies aims to provide compliance officers, law enforcement agencies and legislators with useful insights into the minds of money launderers. Originality/value Whereas most prior literature focuses on money laundering prevention methods, how money launderers operate is not illustrated. This study comprehensively overviews the issue by interviewing not only compliance officers but also money launderers. Understanding how money launderers operate is essential to effectively prevent money laundering. In particular, compliance officers must be able to view money laundering from the criminal’s perspective to sufficiently combat the issue.