Corylated

In this week’s Corylated podcast Rachel and Niece discuss yet another failed UK payment service provider and examine the UK Financial Conduct Authority’s recent track record supervising this market segment. As UK PSPs continue to fail, the FCA would like to speed up authorisations. Niece and Rachel wonder about these plans, as well as the lighter touch crypto regimes developing in the US and UK. Also, Niece tells Rachel about “strong views” aired at the recent US Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) crypto roundtable! 

Links 

Complaints Commissioner’s report on Firm X

FCA statement on Premier FX

FCA payments improvement plan not fully implemented, failed firms’ customers £22.5mn out of pocket

Ziglu’s filings show early regulatory intervention

Fifth payments firm enters special administration under FCA’s watch

US TradFi criticises ‘innovation exemption’ policies

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www.corlytics.com

In this week’s Corylated podcast Rachel speaks to Neil Giles, president of the TraffikAnalysis Hub at UK charity Stop the Traffik. Neil shares his deep expertise in identifying human trafficking through financial transaction data and using persona-based typologies and survivor-informed intelligence.The conversation explores how financial institutions can detect trafficking patterns, the role of typologies, and why getting curious about this crime can help set someone free. 

The episode also covers:

• The growing market for child sexual exploitation and its financial footprint

• Payment service providers and high-risk transactions

• The importance of public-private partnerships (PPP) in fighting trafficking

• Case studies including Operation Fort and the Modern Slavery Intelligence Network

• Why financial institutions should act now without waiting for regulators

Warning: difficult subject matter.

Links

Stop the Traffik

Human trafficking transaction detection needs a bigger financial crime toolkit

UK watchdog has no plans to prioritise human trafficking

Evolving UK people smuggling policy requires new approach from financial crime teams

Compliance Corylated

Corlytics

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In this episode Rachel Wolcott and Lindsey Rogerson discuss third quarter enforcement data provided by Corlytics. 

They begin by reviewing the largest fine of the quarter handed down to fast fashion chain, Shein, by French privacy watchdog Commission nationale de l’informatique et des libertés’ (CNIL). Shein was fined US$175.7 million for multiple breaches of Article 82 of the EU General Data Protection Regulation (GDPR) after an August 2023 investigationproblems with the retailers’ cookies. 

Rachel then explains the enforcement actions which lie behind a record quarter of fines from the Monetary Authority of Singapore (MAS), before moving on to discuss why anti-money laundering and financial crime are the common theme behind many of Q3’s enforcement decisions. 

Finally, they discuss the messages coming from US and UK regulators on future enforcement actions as well as the prospects of more AML-related enforcements from United Arab Emirates. Are enforcements there token gestures or a sign of things to come? 

Links:

Q3 enforcement: Singapore fines and bans for AML failings; Shein’s costly cookies

MAS Takes Regulatory Actions against 9 Financial Institutions for AML-Related Breaches

Cookies placed without consent: SHEIN fined 150 million euros by the CNIL | CNIL

Monzo fined £21 million for fincrime failures, third challenger bank fine inside a year

Weak bank customer due diligence in spotlight again after Barclays fined £42 million

Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and Interactive Brokers LLC | Office of Foreign Assets Control

Transparency International Russia (in Exile): “Gold and Crossbows: How Russian Mercenaries Enable Dirty Business in Africa”

Acting Chairman Pham Announces Successful Completion of Enforcement Sprint

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The Corylated podcast is back with a conversation with Guido Palazzo, professor of business ethics at the University of Lausanne in Switzerland. Guido spoke to Rachel this week about his new book The Dark Pattern.

Join Guido and Rachel for a sobering journey through corporate hell exploring the human toll of some of the worst corporate scandals of recent times. Guido and his co-author Ulrich Hoffrage have identified nine traits of the dark pattern and explain how they manifested at companies from Theranos and Wells Fargo to Uber, Foxconn and FranceTelecom—all scenes of serious corporate malfeasance. Finally, Guido and Rachel discuss how ‘The Bright Pattern’ could help organisations fend off such failings. 

Warning: contains mentions of suicides. 

Links:

The Dark Pattern: The Hidden Dynamics of Corporate Scandals

Guido on LinkedIn

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Corylated on LinkedIn

www.corlytics.com

In this episode Rachel Wolcott and Lindsey Rogerson discuss how the US is diverging from the Rest of the World when it comes to expectation on financial crime expectation and the checks it requires financial institutions to make. 

They begin talking about US Treasury plans to reduce Bank Secrecy Act anti-money laundering obligations for smaller banks. Rachel raises the case of Summit National Bank in Hulett, Wyoming (pop. <400) which had plans to go big in fintech with a Bulgarian crypto company. It did not have ambitious ML/CFT compliance plans, however, and US regulators pulled the plug.

Lindsey and Rachel then switch to discussing the recent fines from the UK Financial Conduct Authority on the so-called challenge banks – Metro, Monzo and Starling bank as well as early action against CB Payments. Most of which can be attributed to prioritising growth in customer number of AML and KYC checks. And Lindsey asks what has happened to an essential annual data publication from the Payments Systems Regulator. 

Finally, they discuss the European Banking Authority’s recent opinion on the state of AML control at European institutions and the UK’s nine System Priorities for tackling financial crime. 

Links:

Main Street banks can have Big City financial crime risks

Summit National Bank, Hulett, Wyoming 

Weak bank customer due diligence in spotlight again after Barclays fined £42 million

Monzo fined £21 million for fincrime failures, third challenger bank fine inside a year - Compliance Corylated

National Crime Authority System Priorities 

UK-Nigeria partnership to detect, disrupt and deter fraud - GOV.UK

EBA Opinion and Report on ML TF risks.pdf 

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In this episode Rachel Wolcott and Lindsey Rogerson discuss the proposed changes to the UK’s landmark Senior Managers & Certification Regime (SM&CR). At its inception it was deemed to be framework proportionate to challenge of holding financial services senior managers accountable, but 10 years on the UK government and regulators view some aspects to be a burden. Rachel and Lindsey look back at the post-Global Financial Crisis landscape that brought SM&CR into being, the lack of enforcement action around the regime as well as some of the proposed changes. 

Links

More senior manager penalties coming, says UK watchdog

Financial Conduct Authority consultation: https://www.fca.org.uk/publication/consultation/cp25-21.pdf 

Prudential Regulation Authority consultation: https://www.bankofengland.co.uk/prudential-regulation/publication/2025/july/review-of-the-senior-managers-and-certification-regime-consultation-paper

HM Treasury consultation: https://www.gov.uk/government/consultations/consultation-reforming-the-senior-managers-certification-regime 

Contact us:

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In this episode Niece Prayoonrat discusses her recent reporting with Lindsey Rogerson. They begin with failed crypto firm, Ziglu. Niece explains how she first became aware that something might be amiss at the group, before moving on to discuss the uncertainty over whether investors will get any money they had in its so-called “boost deposit account” back.

Niece then turns to neo-broker Robinhood’s recent product launch on the French Riviera, and why its regulator – the Bank of Lithuania – has some questions over its Open AI and Space X private stock tokens. They discuss why the regulator’s decision on compliance with the Market in Financial Instruments Directive (MiFID ii) will be hotly watched by financial firms who have a host of alternative asset tokens waiting in the wings.

Finally, they discuss Niece’s Freedom of Information request which revealed the Financial Conduct Authority had spent £300k on influence-led campaigns. They highlight risks to the regulator from the discovery that all off influencer paid by the FCA also earn referral commissions from neo-brokers. And discuss how regulators need to be much clearer with the public on if, and how, money in crypto “deposits” and “funds” is protected.

Links:

Niece’s articles

Exclusive: FCA spent over £300k on 23 finfluencer-led campaigns

Ex-Starling founder’s Ziglu enters special administration

Defunct Ziglu’s finances in doubt last year; directors linked to failed investment firm

FCA: firms should tell us before ‘things go wrong’

Ziglu’s collapse: UK crypto ‘small fry’ struggle to succeed

Regulator seeking clarification on Robinhood's EU stock token launch - Compliance Corylated

FCA creates dedicated ‘neo-broker’ supervision team

Library of Congress archive of New York Stock Exchange investment ad

https://www.youtube.com/watch?v=OQrs6Oa8qtE

In this episode Rachel Wolcott and Lindsey Rogerson discuss the jailing of siblings Redinel and Oerta Korfuzi at Southwark Crown Court in London on July 4. The pair were found sentenced to a combined 11 years after Redinel used his position as an analyst at Janus Henderson to trade on inside information. 

They begin by discussing why the Financial Conduct Authority (FCA) might be a celebratory mood after this and other recent successful insider dealing prosecutions, before considering the details of the judgment and the lessons therein for financial services professionals. 

The conversation then moves on to ponder the presence of Sottish and Northen Irish bank notes in two recent FCA criminal cases. 

Finally, they discuss recent warnings from UK and French authorities about organised criminal gangs increasingly recruiting junior bank staff for their access to insider information. And crucially what systems and controls these institutions need to have in place to detect and notify regulators when they suspect insider dealing. 

Links:

Rachel’s article on the Korfuzi case FCA hails Korfuzi siblings’ long insider dealing sentences

FCA Match Watch 77 – Trading by OCGs Market Watch 77 | FCA 

FCA Match Watch 73 – Market conduct and suspicious trading Market Watch 73 | FCA

AMF and French Anti-Corruption Agency (AFA) call for vigilance on OCGs The AMF and the AFA call for vigilance on the risk of private corruption by criminal networks of natural persons with access to inside information | AMF

Finnish Financial Services Authority June Newsletter on suspicious transaction and order reports (STORs) markkinat-tiedote-2_2025_en.pdf

Responses to the European Securities and Markets Authority (ESMA) paper on insider lists Consultation on the Draft implementing technical standards on the extension of the use of the alleviated format of insider lists

In this episode, Rachel Wolcott and Lindsey Rogerson discuss the UK Financial Conduct Authority’s proposals to apply non-financial misconduct rules to an additional 37,000 regulated firms and lessons from the recent Upper Tribunal decision in the Jes Staley case. 

They begin by recapping the findings from the FCA’s survey of non-financial misconduct which was published last year as way of highlighting why the rule changes to the Code of Conduct (COCON) and Fit and Proper assessments is needed. 

They discuss why compliance and legal professional think guidance will help firms decide what “serious” bullying and harassment look like and most importantly how to deal with the individuals perpetrating such incidents. They also talk reasonable steps for managers who witness -- or are made aware that a member of their team is suspected of – non-financial misconduct. 

The conversation then moves onto consider the implications for financial firms’ senior executives and boards of the recent Upper Tribunal decision against Jes Staley, former CEO of Barclays. 

Links:

July 2021 FCA/PRA joint discussion paper: Diversity and inclusion in the financial sector – working together to drive change https://www.fca.org.uk/publication/discussion/dp21-2.pdf 

September 2023 FCA consultation paper: Diversity and inclusion in the financial sector – working together to drive change https://www.fca.org.uk/publication/consultation/cp23-20.pdf 

March 2024 Treasury Committee Sexism in the City report expresses concern over D&I plans https://committees.parliament.uk/publications/43731/documents/217019/default/ 

October 2024 FCA survey of non-financial misconduct https://www.fca.org.uk/data/culture-non-financial-misconduct-survey-findings 

March 2025 FCA abandons D&I plans https://www.fca.org.uk/news/statements/update-fca-enforcement-transparency-proposals 

July 2025 Non-financial misconduct CP published CP25/18: Tackling non-financial misconduct in financial services

Jes Staley and Jeffrey Epstein: Evidence That Doomed Ex-Barclays CEO’s Career (paywall) 

Upper Tribunal Decision in Staley case: https://assets.publishing.service.gov.uk/media/685d21fec2633bd820a92a52/Staley_v_FCA_decision_for_release.pdf 

This week we’re bringing an episode featuring Ilia Shumanov, board member at Transparency International Russia in Exile and the co-founder of Arctida, a non-profit focused on challenges facing the Russian arctic. Ilia speaks with Rachel Wolcott, Compliance Corylated’s founding editor about their recent collaboration investigating the son of a Russian Duma deputy and alleged gangster who grew up outside Russia in the US and UK private schools. 

Boris Borisovich Ivanyuzhenkov is another wealthy, young Russian with elite connections. Despite his father Boris Viktorovich Ivanyuzhenkov being a high-ranking figure in the legendary Podolsk OCG, young Boris has traveled the world playing tennis and is the director of several property businesses in the US and Europe. He also happens to be best friends with Mikhail Fedotov, son of energy tycoon Viktor Fedotov.

Ilia and Rachel unpack the case and talk about what it says about the challenges for financial crime investigators and journalists! 

Links

The NepoPEP: Alleged Russian gangster’s son’s US property company

The NepoPep: Sons of Duma deputy and UK Conservative party donor run German property businesses

Contact

[email protected] 

Transparency International Russia