Corylated

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 the ‘Golden Youth’ series of articles examining one of the actors involved in multi-billion-pound crypto laundering scheme. 

Ilia and Rachel recently collaborated on an investigation into the Semen Kuksov case. Kuksov, a young wealthy Russian, was jailed in 2024 in the UK after pleaded guilty to laundering £12 million through his cash-to-crypto operation. Ilia and Rachel unpack the case and talk about what it says about Russian sanctions evasion and money laundering methods today.  

Links 

First article: Golden Youth, the new face of Russian money laundering and sanctions evasion 

Second article: The privileged, privately educated Russian who ran a cash-to-crypto MLAAS for other wealthy Russians and drug traffickers 

Third article: Wealthy Gen Z Russian laundered money in luxury properties, claimed ADHD caused offending 

Metropolitan police: Money laundering gang who exploited Russia-Ukraine war jailed (press release)  

Crown Prosecution service: Men jailed for laundering more than £12m of criminal cash (press release) 

Contact: [email protected]  

In this episode, Lindsey and Rachel cover the sentencing of UK art dealer for failing to report suspicion of terrorist financing when dealing with a sanctioned individual. Oghenochuko Ojiri, who was given two and a half years in prison, subscribed to an art market due diligence service, but did not heed its findings.  Mrs Justice Cheema-Grubb told Ojiri during sentencing: “These offences are so severe that only a custodial sentence can be justified. Working in a regulated sector brings responsibilities, but you closed your eyes to what you knew.” 

Listen in for further insights from the sentencing. 

Links:

Jailed UK art dealer ignored due diligence platformʼs alert on Hezbollah financier 

Full sentencing remarks on Sky News Courts 

Compliance Corylated video: Follow the handbags, new reporting rules for high value dealers   

UK Financial Intelligence Unit’s SARs report 2023/24  

Money laundering risks in UK higher education report  

Contact us: 

[email protected]  

In this episode Lindsey Rogerson and Rachel Wolcott discuss the UK Financial Conduct Authority’s updated version of its Enforcement Guide. They begin by recapping on the intentions behind proposals to change the “exceptional circumstance” test for disclosing if/when a financial services firm was under investigation. 

They discuss the entirely foreseeable backlash and justifiable industry concern about naming firms when time for FCA to complete investigations was running at an average of 42 months. 

The conversation then moves onto consider where the consultation landed on transparency and what if anything has really changed.  

Rachel also shares some insight on the cost of prosecuting small scale insider dealing cases on the back of a response she received to a request under the Freedom of Information Act 2000.  

And Lindsey considers whether a House of Lords amendment to the UK Employees Rights might succeed in where PS25/5 failed in encouraging whistleblowers to come forward.  

Links: 

FCA spent over £300k on insider dealing duo who made £43k 

Over 50% of FCA investigations are public 

FCA policy statement 25/5: Our enforcement guide and greater transparency of enforcement investigations  

House of Lords Financial Services Regulation Committee report: Naming and Shaming: How not to regulate  

Recent FCA apologies to Collateral investors, FundingSecure customers, and Basset & Gold minibond investors for slowness in handling complaints about how these firms were authorised and supervised.  

UK financial services firms are still falling short when it comes to their vulnerable customers. The Financial Conduct Authority (FCA) explored the issue in its March review, highlighting that the financial services industry is still not doing enough. To unpack the challenge, Niece Prayoonrat, a reporter at Corylated, speaks to Howard Taylor, a director at PwC’s Risk and Compliance Transformation Consulting practice. 

Howard participated in the FCA’s panel launching its most recent work on vulnerability and has advocated for a needs-led and customer-focused approach to vulnerable customers. He also offers valuable insights as a wheelchair user. 

In this episode, Niece and Howard discuss how organisations and regulators can better serve those who are sometimes left behind. Howard addresses how product and business teams can design products with vulnerable customers in mind, whether a one-size-fits-all approach might actually be harmful, and the overarching vision from current government workstreams. 

Links:

Banks fail vulnerable customers; most UK adults reluctant to disclose status 

UK elderly fraud victims lose £4,000 per scam, research says 

Smart data central to next evolution in banking services 

Delivering good outcomes for customers in vulnerable circumstances – good practice and areas for improvement (UK Financial Conduct Authority) 

Contact us 

e[email protected] 

compliancecorylated.com

In this episode Lindsey Rogerson and Rachel Wolcott begin by discussing why the UK is such a hotbed for fraud and go onto consider the recent drop in authorised push payment (APP) fraud in the UK following the introduction of mandatory reimbursement in October 2024.  

The conversation then moves onto the European Payments Services Directive (PSD3) and how it is being updated in an effort to clampdown on the use of virtual IBANs by fraudsters. The lack of user-friendliness of fraud warning lists issued by European and global regulators is then discussed alongside the Financial Conduct Authority's Register.  

Rachel and Lindsey highlight instances where the Register has been part of the problem in amplifying the “halo” effect of an FCA authorisation before wrapping up the conversation with a look at how fraud is increasingly perpetrated by international criminal gangs and what the UK’s hotly anticipated UK Fraud Strategy might include.  

We’re taking a break and will be back in June with more Corylated. In the meantime, please like, subscribe and leave a 5-star review! Thanks for listening!  

Links: 

Payment Systems Regulator 2024 APP reimbursement data: APP fraud performance data | Payment Systems Regulator 

BBC Panorama episode on Blackmore Bond: https://www.bbc.co.uk/programmes/m001b7jh  

UK could revoke trade and aid in fight against online fraud - Compliance Corylated 

UK elderly fraud victims lose £4,000 per scam, research says - Compliance Corylated 

UK lost $33.2bn to frauds and scams in 2024 - most in EU  

Zelle mentions on Facebook ads ‘correlatedʼ to scams, Meta says   - Compliance Corylated 

PSR shares early findings from APP fraud repay scheme  

In this episode Rachel Wolcott and Lindsey Rogerson discuss the state of play with various sanctions regimes. Following Russia’s invasion of Ukraine in 2022, the United States, European Union, United Kingdom and others imposed sanctions and Russian sanctions are still the big story as the war passed its third anniversary in February. 

The return of Donald Trump to the White House caused initial uncertainty, but this month saw the US renew its Russian sanctions package. The discussion looks at how the US, UK and EU have evolved their Russian sanctions, including a close look at two cases in the UK –involving respectively Dmitriii Ovsiannikov and Mikhail Fridman – to gauge how sanctions enforcement is working. 

The conversation then moves on to consider how sanctions are increasingly being intermingled with tariffs and other trade barriers, examining both the US action against Canada and Mexico over fentanyl trafficking and China’s recent update to its anti-foreign sanctions law. And covers where compliance teams can turn for guidance when navigating the sanctions quagmire. 

Please take a minute to rate this podcast! Your support is appreciated.

Links:

Firms failing to grasp domestic payments’ sanctions risk: https://www.compliancecorylated.com/news/firms-failing-to-grasp-domestic-payments-sanctions-risk/

Sanctions complexity, tough US trade policy boosts risk for fund managers

https://www.compliancecorylated.com/news/sanctions-complexity-us-trade-policy-risk-fund-managers/

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

https://www.compliancecorylated.com/news/evolving-uk-people-smuggling-policy-requires-new-approach-from-financial-crime-teams/

NCA press release on Dmitriii Ovsiannikov https://www.nationalcrimeagency.gov.uk/news/nca-secures-first-convictions-for-breach-of-uk-sanctions#:~:text=Dmitrii%20Ovsiannikov%2C%20the%20former%20Russia,breaching%20the%20UK's%20Russia%20sanctions.

OFSI fine of Herbert Smith Freehills https://ofsi.blog.gov.uk/2025/04/04/hsf-moscow-penalty-key-lessons-for-industry/

US renews Russia sanctions https://www.govinfo.gov/content/pkg/FR-2025-04-14/pdf/2025-06399.pdf  

US lifts sanctions on Karina Rotenberg https://www.occrp.org/en/news/us-lifts-sanctions-on-wife-of-russian-oligarch-boris-rotenberg 

US removes sanctions on Tornado cash https://ofac.treasury.gov/recent-actions/20250402  

In this episode Rachel Wolcott and Lindsey Rogerson discuss the timely arrival of the European Union’s Digital Operational Resilience Act (DORA) and the requirement for UK financial institutions to identify their critical third party suppliers.

The Crowdstrike event last summer highlighted the risk of third party suppliers. The need for such DORA/UK work was furthered underscored in letters sent to the UK parliament’s Treasury Committee in February by the country’s nine largest banks. The breakdown of the cause of every bank outage in the last two year is illuminating – issues at third party suppliers accounted for 24 out of a total 120 outages.

The discussion then turns to what lessons can be learned by compliance and risk teams and also considers how current geopolitical tensions could make things a whole lot worse.

Links:

FCA Crowdstrike lessons learned 

Which? Report on CrowdStrike incident 

Trump’s National Security Firings Come as He Weakens U.S. Cyberdefenses - The New York Times

UK Cyber security and resilience Bill update 

UK’s largest banks paid customers £6.2 million after IT outages

Risk managers under-rate third-party vendors’ GenAI use - Compliance Corylated

EU must exempt firms from DORA’s ICT definitions - Compliance Corylated

Banks need active social media response to viral ‘free money’ posts

https://committees.parliament.uk/committee/158/treasury-committee/publications/3/correspondence/

https://www.iosco.org/library/pubdocs/pdf/IOSCOPD767.pdf

In this episode, Lindsey Rogerson is joined by Elizabeth Lumley to discuss what is happening with open banking and open finance in the UK, EU and elsewhere. The UK used to be a global leader in open banking but with even the chief executive of the Financial Conduct Authority (FCA) saying recently that the country is falling behind the likes of Brazil and India we take a look at what can be done to course correct.  

We discuss what went wrong and what is needed, from government, regulators and incumbent banks to get things moving again and what we could learn from India and Brazil in particular.

The discussion then turns to how regulators can better nurture the start-up and be more sympathetic to requests to explain what and how regulation will impact their businesses. And why every start-up needs a good lawyer. 

Links

Open banking’s promise has yet to deliver

The Centre for Finance, Innovation and Technology’s blueprint for open finance

HM Treasury list of promises from Financial Conduct Authority  

In this episode, we take a look at the growing economic risk from physical climate change and the increasing intensity of natural catastrophes as a result of a warming planet. In Europe only around one quarter of damage from natural catastrophes have historically been covered by insurance, in Asia the figure is 13%. And in the US state of California home sales are falling through because potential buyers cannot procure mortgages due to the risk of wildfires.

We discuss how the European Insurance and Occupational Pensions Authority (EIOPA) and the European Central Bank (ECB) have been leading the way in calling for greater cooperation from governments and private sector to boost resilience to natural catastrophes.

Insurers have been stepping up and we discuss some of the technologies that firms have been adopting to better assist customers, improve resilience, reduce premiums and improve claims. We also take a look at the UK’s Prudential Regulatory Authority’s rejection of measures which have boosted the uptake of insurance-linked securities in Singapore.

Links

Keynote speech by Petra Hielkema at the EIOPA Sustainable Finance Conference - EIOPA

The Impact of an Extreme Cloud Burst on Edinburgh Castle and How Important were Human Influences | Royal Meteorological Society

Events | Royal Meteorological Society

Flooding Stockbridge, Edinburgh https://www.youtube.com/watch?v=hfq7mXVzJ1E

In this episode, we delve into the powerful role social media plays in amplifying and accelerating financial risks. We revisit the 2023 collapse of Silicon Valley Bank, a prime example of a social media fuelled bank run where $40 billion fled in hours after online doubt spread. Experts and regulators, including Janet Yellen, have highlighted how social media can endanger banks through rapid deposit flight.

We also explore how social media amplifies sows distrust in regulators, auditors and the justice system. The episode touches on how strategic leaks and rumours surrounding mergers and acquisitions amplified online.

The rise of finfluencers and their impact on investment decisions, particularly for Gen Z, is also examined. Regulatory bodies like the US SEC and UK FCA are actively addressing unauthorised financial promotions by these social media figures. Finally, we discuss the alarming statistic that 80% of financial fraud in the UK originates on social media, underscoring the urgent need for proactive measures and the implications of the UK’s Online Safety Act. 

Links:

Compliance Corylated, LinkedIN, Corlytics 

https://www.compliancecorylated.com/news/risk-managers-should-adapt-their-toolkits-for-social-media-shocks/

https://www.compliancecorylated.com/news/banks-need-active-social-media-response-to-viral-free-money%ca%bc-posts-misinformation/

https://www.compliancecorylated.com/news/meta%ca%bcs-focus-on-high-severity%ca%bc-violations-will-not-stop-organised-crime/

https://www.compliancecorylated.com/news/children-targeted-by-social-media-recruitment-ads-for-money-mules-financial-exploitation-linked-to-other-harms/

Wall Street Journal Report on Silicon Valley Bank: https://www.youtube.com/watch?v=QACGoKb48_0 

US FDIC report on the Silicon Valley Bank Twitter bank run: https://www.fdic.gov/analysis/cfr/bank-research-conference/annual-22nd/presentations/cookson-presentation.pdf 

Cambridge Disinformation Summit 2025: https://www.jbs.cam.ac.uk/events/cambridge-disinformation-summit-2025/4 

Jagolinzer's keynote speech on systemic risks of information pollution: https://www.linkedin.com/pulse/keynote-speech-systemic-risks-information-pollution-alan-jagolinzer-lqole/?trackingId=P0p87Z1DTIW6EsgTFnfr2w%3D%3D5 

FCA Primary Market Bulletin 54: https://www.fca.org.uk/publications/newsletters/primary-market-bulletin-5411 

CFA Institute report on finfluencer appeal: https://rpc.cfainstitute.org/research/reports/2024/finfluencer-appeal12 

YouTube targeted by deep fake: https://www.youtube.com/watch?v=P5N087Hdsc0 

Spyware on phones:

https://www.youtube.com/watch?v=WLbHs_S-Fzc 

https://www.theguardian.com/technology/2025/jan/31/whatsapp-israel-spyware 

Anti-DEI and airlines: https://www.youtube.com/watch?v=qdJLUH95CHA