Integrity Insights

This is a conversation with Polly Sprenger, a lawyer specialising in private prosecutions, corporate crime, fraud investigations and asset tracing, about how complex fraud cases are investigated and ultimately brought before the courts.

We discuss Polly’s unusual career path from journalism and corporate intelligence to the Serious Fraud Office and legal practice, and how the standards for gathering and testing information change when evidence has to withstand scrutiny in court.

Polly explains how private investigations can support victims when law enforcement cannot or does not pursue a case, how investigators follow money and defendants across multiple jurisdictions, and why unlawfully obtained information can create serious problems for an investigation.

We also discuss a major cross-border investment fraud case involving victims in the United States, defendants in the UK and Germany, and funds moving through jurisdictions including Hong Kong, Dubai, Bosnia and Croatia.

Finally, we look at how artificial intelligence is changing legal investigations. Polly explains how AI is already accelerating document review, chronology building and evidence analysis – while also warning against relying on AI to interpret the law itself.

The episode is relevant for listeners working in investigations, corporate intelligence, fraud prevention, asset recovery, financial crime, litigation, OSINT and legal services.

Polly Sprenger:   / polly-sprenger-a406686 

Keystone Law: https://www.keystonelaw.com/

Integrity Insights Podcast: https://pod.link/1691491946

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In this episode, Integrity Insights host Filip Brokes is joined by Vlada Tkach, Managing Partner at Berlin Risk, and Verena Horne, Director at Berlin Risk, to discuss what background checks and integrity due diligence can uncover in practice.

Drawing on anonymised cases from their work at Berlin Risk, Vlada, Verena and Filip discuss a senior executive who retained a concealed interest in a competitor, a purported Hong Kong investor whose multibillion-dollar infrastructure claims proved fictitious, and a supposed Turkish construction group that was effectively a one-person operation.

The conversation also examines investment funds linked to a sanctioned associate of Vladimir Putin, corruption allegations surrounding a Central European manufacturer ahead of its IPO, and the importance of combining public-record research with human-source enquiries.

Filip, Vlada and Verena explain how investigators assess and contextualise reputational, regulatory, sanctions, political-exposure and financial-crime risks – and how due diligence can help organisations avoid problematic investments, appointments and business relationships without necessarily preventing legitimate transactions from proceeding.

The episode is relevant for listeners working in integrity due diligence, compliance, AML/CFT, sanctions, investment risk, corporate intelligence, OSINT and investigations.

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Professional football moves enormous sums of money across borders, often at speed and through complex ownership and payment structures. But are the financial controls around those transactions keeping pace?

In this episode of Integrity Insights, Filip Brokes speaks with James Kitching, an Australian sports lawyer, former FIFA Director of Football Regulatory and founder of The FC, about the regulation of football’s global transfer system and the financial crime risks surrounding it.

James explains how his career took him from white-collar crime enforcement in Australia to the Asian Football Confederation and FIFA, where he helped develop major regulatory reforms, including the FIFA Clearing House. He discusses how the system automates the payment of training rewards to clubs, while introducing KYC, beneficial ownership, sanctions and source-of-funds checks into parts of the transfer process.

The conversation also examines the European Union’s decision to bring professional football clubs within the scope of AML/CFT regulation from 2029. James considers why football is viewed as a high-risk sector, whether clubs are prepared for the new requirements, and whether the EU approach could eventually influence football regulation more widely.

The episode offers a practical look at football governance, transfer payments, financial compliance and the challenge of applying conventional AML controls to a fast-moving global industry.

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In this episode of Integrity Insights, Filip Brokes speaks with Emmanuelle Saliba, Chief Investigative Officer at Get Real, about deepfakes, synthetic identities and AI-driven identity fraud. They discuss how generative AI is changing misinformation, social media manipulation, voice cloning and remote identity verification, with a focus on what these risks mean for businesses, governments and individuals. The episode is relevant for listeners working on corporate security, financial crime, fraud prevention, cybersecurity, OSINT and digital investigations.

Topics covered

Deepfakes and synthetic media
Visual verification and investigative journalism
How online misinformation has evolved
Why simple deepfake “tells” are no longer reliable
AI-generated influencers and synthetic personas
Commercial scams and engagement farming
Political influence operations and synthetic social media accounts
Voice cloning and real-time impersonation
Deepfakes in war and crisis situations
Provenance, watermarking and verification standards
Corporate exposure to AI-driven identity threats
Remote identity verification and synthetic IDs
Deepfake-resistant security systems
The threat horizon for businesses, governments and individuals

Emmanuelle Saliba: https://www.linkedin.com/in/emmanuellesaliba/ 

GetReal: https://www.getrealsecurity.com/ 

GetReal Youtube: https://www.youtube.com/@GetRealSecurity 

Watch The Whole Podcast On Youtube: https://www.youtube.com/watch?v=St4FL0OmKjk&t=260s

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In this episode of Integrity Insights, host Filip Brokes speaks with Thom Townsend, Executive Director of Open Ownership, about the evolving global landscape of beneficial ownership transparency.

The conversation revisits one of the major turning points in the transparency agenda: the November 2022 Court of Justice of the European Union ruling, which restricted unrestricted public access to beneficial ownership registers. Thom explains how the decision created a “seismic shift” in Europe and beyond, prompting some jurisdictions to pause reforms or reassess public access models. At the same time, he highlights that the ruling also confirmed an important role for civil society, journalists and academia in fighting money laundering through access based on legitimate interest. 

The discussion also looks at the United States, where the rollback of the Corporate Transparency Act has added further uncertainty to the global reform agenda. Thom reflects on what this could mean for FATF standards, mutual evaluations and the incentives facing countries that are still considering or implementing beneficial ownership reforms.

A key theme of the episode is the difference between a register that merely exists and one that is genuinely useful. Thom explains why usability depends not only on whether data is accessible, but also on whether users can search by company and individual names, identify links across entities, access structured data, and rely on systems that support verification and cross-checking. He discusses examples from jurisdictions including Nigeria, Botswana, Austria, Denmark, Norway, South Africa and Argentina, showing that there is no single model for success.

The episode also explores the practical challenge of verification. Thom distinguishes between verifying the identity of a natural person and verifying whether that person genuinely owns or controls a company. He explains why verification is a “team sport” requiring discrepancy reporting, cross-government data sharing, tax-data checks, land and property registers, and credible deterrence mechanisms.

Despite political and legal headwinds, Thom remains broadly optimistic. He notes that around 150 to 160 jurisdictions have implemented, are implementing, or plan to implement beneficial ownership reforms, and argues that the global evidence base around beneficial ownership transparency is growing rapidly.

Documents referenced: 

1. The usable data framework - https://www.openownership.org/en/publications/usable-beneficial-ownership-data/ 

2. The Open Ownership map https://www.openownership.org/en/map/ charts progress globally.

3. Open Ownership's reaction to AML6 https://www.openownership.org/en/news/european-union-takes-important-steps-towards-standardised-and-interoperable-beneficial-ownership-information/

4. Open Ownership's response to the 2022 CJEU verdict https://www.openownership.org/en/news/statement-on-court-of-justice-of-the-european-union-cjeu-judgement-on-public-beneficial-ownership-registers-in-the-eu/

5. The launch of Open Ownership's new research project, BEAM https://www.openownership.org/en/blog/from-reform-to-results-introducing-beam-a-new-programme-to-measure-impact-in-beneficial-ownership-transparency/, which will work with researchers and academics to design more ways to measure the impact of BO information.

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In this episode of Integrity Insights, Filip Brokes is joined by Verena Horne (Director at Berlin Risk) and Davids Alksnis (Consultant at Berlin Risk) to discuss the fundamentals of background checks and due diligence investigations.

The conversation provides a practical overview of how integrity due diligence works in real-world scenarios, why clients rely on external investigators, and how risks are identified, assessed, and communicated.

Key themes discussed

•  Background checks vs. due diligence
   The episode clarifies the distinction between the two terms: background checks as an initial screening process, and due diligence as a more in-depth, structured investigation aimed at fully assessing risks. 
•  Why clients commission investigations
   Clients typically seek due diligence when facing uncertainty around key decisions, such as investments, partnerships, market entry, or senior hires. The core objective is to understand who they are dealing with and what risks may arise. 
•  Types of risks assessed
   Investigations focus on a wide range of risks, including reputational concerns, source of wealth, sanctions exposure, governance issues, business track record, and behavioural red flags (including online conduct). 
•  Methodology and approach
   The discussion highlights the importance of a structured methodology based on the intelligence cycle: defining the research question, collecting relevant data, verifying sources, and producing actionable analysis rather than raw information. 
•  OSINT and human source inquiries
   While open-source research forms the foundation, many cases require human source inquiries to provide context, validate findings, and uncover information not available in public records. 
•  Jurisdictional challenges
   The availability and reliability of information vary significantly across jurisdictions. Differences in corporate transparency, media landscapes, and cultural norms can materially impact investigative approaches. 
•  Case example: uncovering fraud
   The episode includes an anonymised case where a seemingly credible company bidding for a major contract was ultimately revealed to be a fraudulent front for an individual with a history of criminal activity. 
•  Working with limited or excessive information
   Investigators must navigate both data overload and data scarcity. In low-information cases, creativity and alternative data sources become critical, while high-volume cases require careful filtering and prioritisation. 
•  The impact of AI on due diligence
   AI is increasingly used to process large volumes of information efficiently. However, the discussion emphasises the growing importance of verification, critical thinking, and human judgment, given issues around reliability, consistency, and trust.

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In this episode of Integrity Insights, Filip is joined by Skip Schiphorst of i-Intelligence, a specialist in multilingual open-source intelligence and online research. Skip manages the company’s language-focused OSINT courses, including Chinese, Russian, and Arabic.

The conversation explores a frequently overlooked aspect of OSINT: how to research effectively in foreign languages even if you do not speak them fluently. Skip explains why accurate searching in Arabic, Chinese, and Russian is about far more than translation, and why cultural, political and linguistic context remains essential despite the rise of AI tools.

Key themes discussed

• Language-based OSINT as a specialist discipline
   Skip explains how i-Intelligence trains analysts, journalists, and corporate investigators to search in foreign languages using the right methodology.
• Why translation alone is not enough
   The discussion highlights the limits of Google Translate, AI tools, and literal transliteration when researching foreign companies, individuals, or media sources. Getting the exact local spelling or company name right is often the key to the entire investigation.
• Culture, politics, and context
   Skip emphasizes that language research cannot be separated from local context. Understanding naming conventions, media ecosystems, religion, politics, and regional culture is often essential to interpreting sources correctly.
• Vetting foreign-language sources
   The episode looks at the challenge of judging the reliability of local sources, especially in politically sensitive environments, and why building human networks and simply asking trusted local contacts can be as important as technical search skills.
• AI versus methodology
   Skip reflects on how analysts increasingly turn to AI first, but argues that strong methodology still outperforms overreliance on large language models. In his view, AI can support research, but it cannot replace sound analytical thinking.
• Do you need to speak the language?
   One of the central themes of the episode is that speaking a language and knowing how to research in it are not the same thing. Skip argues that non-native speakers with strong methodology can often outperform native speakers who lack OSINT training.
• Why learning languages still matters
   The conversation closes on the enduring value of language learning, both for research and for human understanding more broadly, especially at a time of increasing geopolitical fragmentation and polarization.

Links:

Searching the Chinese Internet: Foundations Course

https://i-intelligence.eu/courses/searching-the-chinese-internet-foundations

OSINT: Searching the Russian Internet Course

https://i-intelligence.eu/courses/osint-searching-the-russian-internet-virtual-course

OSINT: Searching the Middle Eastern Internet Course

https://i-intelligence.eu/courses/osint-searching-the-arabic-web

Connect with Skip:

LinkedIn:

https://www.linkedin.com/in/skip-schiphorst-721bb6200/

Skip's Instagram page where he shares his language learning techniques 

https://www.instagram.com/skipmovestolearn/

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In this episode of Integrity Insights, we are joined by Nico Dekens, a recognized authority in the world of open-source intelligence (OSINT). With over 30 years of experience in the field, Nico shares his insights into the evolving OSINT landscape, the tools and techniques he uses, and the ethical considerations of this critical field. Nico spent over two decades with the Dutch police, working on intelligence and human operations, before transitioning to the private sector where he now leads engineering efforts at Shadow Dragon.

We dive into how OSINT has changed over the years, with new technologies such as AI revolutionizing the process, but also the complexities of using these tools responsibly. Nico shares practical advice on how to start an OSINT investigation, how AI and machine learning are reshaping the future of intelligence, and how to stay up to date in a fast-evolving field. He also gives us a glimpse into his work on high-profile cases, where he uses his investigative skills to piece together puzzles from seemingly limited data.

Key Takeaways:

• The Evolution of OSINT: Nico provides an overview of how OSINT has progressed over the past three decades, with a focus on the increased integration of AI and machine learning in the investigative process.
• Practical OSINT Techniques: Nico explains his approach to conducting investigations, from starting with a name or photo and using facial recognition tools to building actionable intelligence.
• The Ethics of OSINT: Nico discusses the ethical boundaries of OSINT, focusing on the use of publicly available data and the challenges of navigating the dark web and leaks without crossing legal or ethical lines.
• AI and OSINT: While AI tools provide huge advantages in terms of processing large data sets, Nico emphasizes that human judgment remains critical for interpreting and validating the data.

Time Stamps:

• 00:00 – Intro & Background: Nico’s professional journey and his transition from the Dutch police to Shadow Dragon.
• 04:20 – OSINT Techniques: How Nico begins an investigation and the tools he uses, including facial recognition software.
• 10:00 – The Ethics of OSINT: Discussing the ethical challenges and limitations of OSINT, including using publicly available data.
• 15:30 – The Role of AI in OSINT: How AI and machine learning are changing the field and the importance of human oversight.
• 21:45 – The Future of OSINT: The rise of commercial OSINT, network-building in the community, and keeping up with the fast pace of technological change.

Relevant Articles:

• The Slow Collapse of Critical Thinking in AI – Nico’s recent article exploring AI’s limitations in OSINT.
• OSINT is Still a Thinking Game – Discussing the balance between technology and human input in OSINT investigations.

Listen to the Episode:

• Available on Spotify
  , Apple Podcasts
  , and Amazon Music

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AML CFT Roundup 2025: What changed, and what comes next

In this episode of Integrity Insights, Filip is joined by Jennifer Hanley-Giersch to review the biggest AML/CFT developments of 2025. They discuss why the year marked a shift from incremental updates to structural change, driven by AMLA’s launch, preparation for the EU Single Rulebook, tougher sanctions expectations, and a renewed focus on terrorist financing.

Key themes discussed

• AMLA and the EU Single Rulebook
   Although the regulation applies from July 2027, firms face earlier deadlines. From October 2026, national supervisors will collect new risk and controls data to feed AMLA’s risk-scoring model, forcing many institutions to remediate data gaps.
• FinTech and RegTech under pressure
   Supervisors reported rising risk from FinTechs, often linked to weak governance and immature controls. Jennifer highlights that many serious failures involve poorly implemented RegTech tools and lack of expertise.
• Germany: BaFin guidance and FIU progress
   BaFin’s updated guidance increased expectations around risk assessments (including separating money laundering and terrorist financing risk), residual risk, outsourcing oversight, AML officer responsibilities, and customer data update cycles. The German FIU also reported fewer but higher-quality STRs, with more referrals to law enforcement.
• Terrorist financing and crypto enforcement
   Crypto remains a major risk area, but 2025 showed stronger enforcement momentum, including disruption of terrorist fundraising and takedowns of anonymisation infrastructure such as mixers.
• Sanctions and circumvention
   The episode highlights evolving circumvention models linked to Iran and Russia, and the continued willingness of EU and US authorities to impose substantial penalties where firms knowingly facilitate sanctioned interests.
• Cyber fraud and operational resilience
   They close with the growing impact of cybercrime and DORA-driven supervision of critical ICT providers, reinforcing that resilience is now a core component of financial integrity.

Key takeaway: 2025 accelerated the move toward centralised supervision, higher data expectations, and closer links between AML, sanctions, crypto, and cyber resilience.

Related content: 

AMLA's work program: https://www.acams.org/en/opinion/amlas-work-program-and-its-enhanced-oversight-of-casps 

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In this episode of Integrity Insights, host Filip Brokes is joined by Professor Niels Appermont, a professor of economic law at Hasselt University in Belgium, and an expert in sports law. Neils discusses his research into money laundering in football, with a particular focus on Belgium’s fight against corruption and the broader challenges of enforcing anti-money laundering (AML) regulations in the sport.

Niels shares insights into the Operation Zero scandal, a 2018 Belgian investigation that exposed widespread corruption, money laundering, and match-fixing in professional football. The investigation led to reforms in Belgium's legal framework, including the introduction of AML regulations for football clubs.

Key themes discussed:

• The scope of money laundering in football: Neils explains how football has long been a target for illicit financial flows, with many clubs and agents using shell companies, false invoicing, and match-fixing to cover up corruption and illegal activities.
• The Belgian response: After Operation Zero, Belgium introduced AML regulations that cover professional football clubs, making them responsible for client identification, beneficial ownership checks, and monitoring potentially suspicious transactions.
• Key challenges: Neils discusses the practical difficulties Belgian football clubs face when implementing AML measures designed for the financial sector. These include issues with defining who qualifies as a “client” and dealing with the complexity of football transactions such as player transfers and sponsorship deals.
• International lessons: We also compare Belgium’s experience to the upcoming EU-wide AML regulation for football clubs, set to take effect in 2029. Neils explains the key differences and areas where Belgium has been a pioneer in implementing AML measures in football.

Key Takeaways:

• Money laundering in football is a significant problem, but it's hard to quantify due to the opaque nature of the sector.
• Belgium's proactive stance on AML in football makes it one of the few countries in the EU to regulate football clubs under AML obligations.
• Football clubs face unique challenges when trying to implement AML measures due to the complex nature of football transactions and the international scope of the sport.
• The upcoming EU-wide AML regulations for football clubs could lead to a fragmented approach that may not fully address the sector’s risks.

Listen now to explore the intersection of football, corruption, and financial crime and learn more about the evolving regulatory landscape in European football.

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