Integrity Insights

In this episode of Integrity Insights, Filip is joined by Michael Hornsby and Elisabetta Marinoni, researchers working with Transparency International and the Anti-Corruption Data Collective (ACDC), to discuss their new study: the Opacity in Real Estate Ownership (OREO) Index.

The conversation explores how opaque real estate ownership structures enable corruption and money laundering, why data and legal frameworks both matter, and what their assessment of 24 jurisdictions reveals about global weaknesses in this sector.

Key themes discussed:

Why real estate matters for financial crime

Real estate remains a preferred vehicle for laundering illicit funds. High-value transactions and the ability to hide behind corporate structures make it attractive to corrupt actors and criminals.

What the OREO Index measures

The index evaluates 24 jurisdictions, including G20 economies and major financial hubs such as Hong Kong, Singapore, Panama and the UAE.
It assesses two pillars:

• Data – the availability, completeness and openness of property and ownership data.
• Legal framework – the strength of AML rules governing real estate transactions and professionals.

The biggest loophole: missing beneficial ownership data

Most countries do not collect beneficial ownership information when property is registered.
This means properties can be owned anonymously through companies, especially foreign companies, making it extremely hard for authorities or journalists to trace real ownership or identify patterns of suspicious acquisitions.

Cross-border gaps and obstacles for investigators

Foreign companies can often buy property without any local presence, meaning no local BO disclosure. Investigators must then rely on the rules—and cooperation—of the company’s home jurisdiction, which is often limited or opaque.

Cash purchases and absence of gatekeepers

Some countries allow property purchases in cash and do not require involvement of notaries or lawyers.
This bypasses banking-sector AML controls and removes an important oversight layer.

Uneven AML obligations for real estate professionals

While most countries extend AML requirements to real estate agents, developers and lawyers are often excluded, creating entry points for money laundering.
In some jurisdictions, lawyers can even refuse to submit suspicious transaction reports due to client-privilege provisions.

Weak supervision and fragmented oversight

Supervision is often fragmented across many bodies—Germany, for example, has over 300 supervisory authorities in the non-financial sector—making consistent enforcement difficult.

How jurisdictions compare

• South Africa ranks high on paper, but enforcement gaps remain.
• Germany scores well legally but poorly on data transparency.
• Singapore and Hong Kong perform relatively well, though Hong Kong maintains weaker BO rules.
• The UAE scores poorly, reflecting high anonymity and the “open door” model that has historically attracted illicit funds.

Future outlook: risks of backsliding

Despite years of debate, there is still no global consensus that beneficial ownership transparency in real estate is essential. 

Read the full report here: https://www.transparency.org/en/publications/opacity-in-real-estate-ownership-index-2025 

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In this episode of Integrity Insights, Filip is joined by Daniel Shkedi, Head of Product Marketing and Strategy at Refine Intelligence, a fraud prevention company. He is also a fraud and threat intelligence researcher specializing in cybercriminal activity on the dark web and Telegram. His publications cover a wide range of topics, including online fraud prevention (in banking, eCommerce, and payments), identity validation, emerging threats in underground forums, and AI-driven fraud and eCrime.

The conversation dives deep into the emerging field of Money Laundering as a Service (MLAS) and how cybercriminals are adapting their operations. Daniel provides insights into his research, the typologies of money laundering services offered on the dark web, and why financial institutions need to pay attention to this growing threat.

Key themes discussed:

Money Laundering as a Service (MLAS)
Daniel describes his recent project, where he mapped out how organized criminal groups provide money laundering services to fraudsters on platforms like Telegram and the dark web. This “business” mirrors legitimate financial services in sophistication and scale, making it a rapidly growing problem for financial institutions.

Typologies of Money Laundering
Through his research, Daniel identified several key typologies of money laundering services, including:

• Bank Drops: Rented or sold bank accounts used for cash-out services.
• Bank Loaders: Criminals who move funds onward to bank drop accounts.
• End-to-End Money Laundering Services: Criminal enterprises offering full money laundering packages, including layering and integration.
• Shell Companies and Insider Services: Fraudsters offering to set up fake companies or bank insiders selling stolen financial data.
• Street-Level Cash Outs: Basic services where criminals withdraw funds using stolen or fraudulently obtained bank accounts.

Global Scope of Money Laundering
Daniel shares his findings on how these services are not limited to a single region, but are a global phenomenon. The services are available across North America, Europe, Latin America, Asia, and the Pacific, with different nuances depending on the jurisdiction.

Why Institutions Should Care
Beyond regulatory compliance, Daniel emphasizes that money laundering and fraud expose financial institutions to serious reputational risks, financial losses, and operational disruptions. Criminal enterprises are evolving, and financial institutions must adapt by building proactive threat intelligence programs.

The Role of Threat Intelligence
Daniel outlines how threat intelligence plays a pivotal role in understanding fraud enablers, monitoring their infrastructure, and predicting where future attacks might come from. By gathering data from multiple sources, including the dark web and Telegram, financial institutions can develop comprehensive threat intelligence strategies to stay ahead of cybercriminals.

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In this episode of Integrity Insights, Filip is joined by Jan Indra, a threat intelligence specialist with a decade of experience in financial crime prevention. Jan began his career as an investigative journalist, later moved into consultancy and long-term due diligence projects, and now focuses on researching the ecosystem that enables fraud to flourish.

The conversation dives deep into how fraudsters operate today and why understanding their infrastructure — not just individual cases — is crucial for prevention.

Key themes discussed:

• The evolution of financial crime tactics
  Fraud doesn’t happen in isolation. Jan explains how fraudulent documents, fake identities, and suspicious transactions are all interlinked, often forming part of wider, industrialised schemes.
• Template farms
  Jan describes how websites and Telegram channels openly sell editable templates of bank statements, IDs, utility bills, pay slips, invoices, and even death certificates. These “farms” are easy to find with a simple Google search, often optimized with SEO to reach the widest audience. He explains the different formats offered (PDFs, PSDs, generators that batch-produce fake documents), and the scale — hundreds of thousands of fraudulent templates in circulation.
• Account farms
  Beyond fake documents, entire verified accounts are now being sold — from bank and fintech logins to crypto exchange profiles and remittance service accounts. This trend shows how quickly fraud enablers adapt, and why institutions need to anticipate emerging threats.
• Success rates and risks
  Not all fake documents succeed in slipping through controls, but even a small percentage poses huge problems at scale. Jan discusses how quality of the fake, institutional risk appetite, and the robustness of KYC processes determine outcomes. Some institutions may see 5% fraudulent submissions; others up to 20%, with major operational and financial consequences.
• Geographies and actors
  While much of the infrastructure is anonymised and globally distributed, Jan outlines investigative clues about where some operators may be based, their backgrounds, and how underground economies of fraud overlap with mainstream online spaces.
• Why institutions should care
  Beyond regulatory compliance, fraud enabled by weak KYC systems carries heavy reputational risk, potential for serious financial losses, and operational disruption when organised groups exploit vulnerabilities at scale.
• The role of threat intelligence
  For Jan, threat intelligence means systematically researching fraud enablers, understanding their modus operandi, and mapping the ecosystem. This knowledge is the first step toward prevention — ensuring organisations aren’t always several steps behind the attackers.

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In this episode of Integrity Insights, we speak with Casey Michel, investigative journalist and Head of the Kleptocracy Program at the Human Rights Foundation in New York City. Casey is the author of American Kleptocracy and Foreign Agents, two seminal books on the mechanisms of global illicit finance and foreign influence operations.

Our discussion focuses on the United States’ recent retreat from its longstanding leadership in global anti-corruption efforts. Casey explains how key legislative tools, such as the Corporate Transparency Act (CTA) and the Foreign Corrupt Practices Act (FCPA), are no longer being meaningfully enforced—despite being landmark steps in combating financial secrecy and foreign bribery just a few years ago.

We explore:

• Why the U.S. became the world’s biggest hub for illicit finance.
• How lobbying efforts and state-level interests undermined the CTA.
• The implications of the Department of Justice’s recent decision to narrow FCPA enforcement to matters of "U.S. strategic interest".
• Concerns that enforcement tools are being politicised, potentially weaponised against foreign or domestic political opponents.
• How these rollbacks have severely damaged U.S. credibility and leadership in global anti-corruption efforts.

Casey also places this regression in historical context, suggesting we may be in a modern “Gilded Age” but offers hope by pointing to past cycles of reform following periods of entrenched corruption.

Finally, we ask: can anyone step into the void left by the U.S.? While no single actor currently matches the scope of American enforcement powers, Casey sees signs of renewed leadership from Europe—particularly in the UK, France, and Switzerland—and stresses the need for greater transnational coordination going forward.

Listen to this episode for a deep dive into the shifting landscape of anti-corruption enforcement and what it means for democracies around the world.

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In this episode, host Filip Brokes is joined by Pav Gill, former Head of Legal for the Asia Pacific region at Wirecard and current Founder & CEO of Confide Platform. Pav shares his extraordinary journey from a career at prominent international law firms to becoming a whistleblower who helped expose one of Europe’s biggest corporate scandals.

Pav discusses his entry into Wirecard, explaining the context in which he was headhunted for the role, unaware of the fraudulent activities occurring at the highest levels of the company. He provides insights into the internal workings of Wirecard’s Singapore office, his initial positive experiences, and the unexpected discoveries that led to his whistleblowing.

Listeners will hear the rationale behind Pav’s decision to remain anonymous during the initial stages of whistleblowing, his collaboration with investigative journalists at the Financial Times, and the strategic considerations behind the disclosure of his identity in the media and the acclaimed Sky documentary.

Pav reflects on his post-Wirecard career trajectory, highlighting the challenges he faced in returning to the workforce and how his whistleblower status later became a unique asset. He provides thoughtful analysis on the role of short-sellers in uncovering corporate misconduct, offering balanced perspectives on the ethical dimensions of their activities.

The conversation shifts to Pav’s entrepreneurial journey with the launch of Confide Platform—a compliance-tech startup focused on whistleblowing and compliance reporting. Pav explains his motivation for creating a secure, trusted solution designed to empower organizations to identify and manage internal issues proactively, thereby preventing scandals similar to Wirecard.

The episode also delves into broader regulatory discussions, with Pav offering a comparative analysis of global whistleblowing frameworks. He evaluates the strengths and weaknesses of the EU Whistleblower Directive and explores regulatory trends in Asia, Europe, and the US, including recent political influences on regulatory enforcement.

To conclude, Pav stresses the importance of compliance professionals staying apolitical and diligently focused on applying existing regulatory standards, irrespective of broader political dynamics.

Recommended Resources by Pav Gill:

• Sky Documentary: Wirecard: A Billion Euro Lie
• Book by Dan McCrum (FT Reporter): Money Men
• Financial Times Article: The long-form FT exposé detailing Pav’s whistleblower journey (September 2021).

About Pav Gill:
Pav Gill is a lawyer and compliance expert based in Singapore. Following his critical whistleblower role in exposing Wirecard, he founded Confide Platform, an end-to-end whistleblowing and compliance management tool designed to strengthen corporate integrity globally.

Integrity Insights is produced by Berlin Risk Advisors GmbH

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 In this episode, host Filip Brokes sits down with Carsten Giersch, Senior Partner at Berlin Risk Advisors and Managing Partner at ALL AML, for a wide-ranging discussion on how geopolitical events affect global financial markets. Recorded live at the FIBE conference in Berlin, this conversation dives into topics such as current trade tensions, the psychological dimensions of policy decisions, and how both businesses and governments can respond to shifting geopolitical landscapes.

Key Topics & Takeaways

1. Carsten’s Background
   • Academic history in Political Science, with a focus on international relations and conflicts.
   • Move to consultancy 15 years ago, co-founding Berlin Risk Advisors and ALL AML.
   • Specialization in due diligence investigations, integrity checks, and external money-laundering compliance.
2. The Trump Era and Geopolitical Shifts
   • How President Trump’s approach changed the global risk climate.
   • The interplay of “hard” geopolitical risks with “soft” psychological factors in policy-making.
   • The concept of an “imperial presidency” and how it erodes traditional checks and balances.
3. Impact of Tariffs and Trade Policies
   • The legal loophole behind imposing tariffs through a declared “national emergency.”
   • Potential consequences of escalating trade wars on global markets.
   • Why perceptions of fairness and status matter more than purely rational economic logic.
4. European Responses and Strategies
   • The possibility of EU retaliation via tariffs and/or regulatory measures on services.
   • Alternative strategies for Europe: new free trade agreements, investment in AI, green tech, and collaborative defense.
   • The need for regulatory balance: building resilience (e.g., through AML regulations) without stifling innovation.
5. Cultural Factors in Entrepreneurship
   • Comparing U.S. risk culture to Europe’s more conservative regulatory environment.
   • Potential reforms in education and policy to foster entrepreneurial spirit within the EU.
6. Outlook for Globalization
   • Why the rise of nationalist sentiments doesn’t necessarily mean an end to globalization.
   • The importance of free trade partnerships, from Latin America to Asia, for Europe’s future.
   • Opportunities for the EU to play a leading role in an era of uncertainty.

Quotes

• “It’s both about hard facts on one hand and about psychology on the other.”
  Carsten on why Trump’s policies have sparked greater volatility than previous administrations.
• “Loss aversion and status-based motivations can drive political decisions more than raw economic logic.”
  Carsten highlighting the psychological underpinnings of trade wars.
• “This crisis is also an opportunity for the EU to define a more progressive, open-minded agenda.”
  Carsten discussing how Europe can capitalize on U.S. isolationism to strengthen its own competitiveness.

References & Further Reading

• Berlin Risk Advisors – https://berlinrisk.com/ 
• ALL AML – https://allaml.eu/ 
• International Emergency Economic Powers Act (1977) – The U.S. legislation Trump invoked to impose tariffs - https://www.congress.gov/crs-product/R45618 

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In this episode of Integrity Insights, host Filip Brokes is joined by two seasoned experts to discuss information security, an increasingly crucial issue impacting businesses and institutions globally.

Filip speaks with Annette Farrenkopf, Information Security Officer at Berlin Risk Advisors, and Christian Stehle, Founder and Managing Director of MindBytes, an IT security company based in Germany.

Annette shares her career journey from managing an advertising agency to spearheading information security and data protection at Berlin Risk. She explains information security through its three fundamental principles: confidentiality, integrity, and availability. Emphasising the risks of financial loss, reputational damage, and potential harm from compromised data, Annette highlights the growing necessity for robust security measures, citing a recent KPMG study indicating over one-third of German companies suffered from cybercrime incidents between 2023 and 2024.

Christian introduces MindBytes and describes its services, specialising in penetration testing and red teaming—ethical hacking practices aimed at proactively identifying vulnerabilities before malicious actors exploit them. He elaborates on the difference between these methods and underscores the critical role of open-source intelligence (OSINT) in preparing and executing realistic cyber-attacks to test organisations’ defences.

The episode also explores the EU’s Digital Operational Resilience Act (DORA), implemented in January 2025, highlighting its impact on financial entities and their tech service providers. Annette provides insights into DORA’s significance for the financial sector, while Christian emphasizes the necessity of such regulatory frameworks in an increasingly interconnected digital landscape.

Key topics covered in this episode:

• Understanding information security and its importance
• Ethical hacking: penetration testing vs. red teaming
• Utilising OSINT for security assessments
• Impact of the Digital Operational Resilience Act (DORA) on financial entities and technology providers

Tune in to gain valuable insights from experts navigating the complex landscape of information security.

Host: Filip Brokes Guests: Annette Farrenkopf (Berlin Risk Advisors),  Christian Stehle (MindBytes)

Produced by Berlin Risk 

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In this episode of Integrity Insights, our host Filip Brokes sits down with Daniel Eriksson, the former CEO of Transparency International, for an in-depth discussion on the global fight against corruption. Daniel shares his career journey, his transition from a technology and security background to leading one of the most recognized anti-corruption organizations in the world, and the core mission of Transparency International (TI).

Key Topics Covered:

• Daniel’s Career Path to CEO of Transparency International
  • From IT and cybersecurity to humanitarian work and global governance.
  • Experiences working across 12 different countries.
• Transparency International’s Global Mission
  • Beyond the widely known Corruption Perceptions Index (CPI).
  • The SHE strategy: Making it harder to Steal, Hide, and Enjoy illicit wealth.
  • TI’s seven key strategic pillars:
    1. Protecting public resources (e.g., public procurement and environmental protections).
    2. Combating illicit financial flows and money laundering.
    3. Strengthening political integrity and fighting election corruption.
    4. Ensuring business integrity and responsible corporate governance.
    5. Ending impunity by holding corrupt actors accountable.
    6. Defending civic space and supporting whistleblowers.
    7. Engaging youth and women as key drivers of change.
• Corruption Perceptions Index (CPI)
  • How it’s measured: 13 data sources normalized into a composite index.
  • Why it’s a perception-based ranking and its global influence.
  • Limitations of the CPI and misconceptions about its interpretation.
  • Pushback from governments unhappy with their rankings.
• Global Trends in Corruption
  • Ukraine’s rapid progress in fighting corruption post-2014.
  • The erosion of democracy in regions like Georgia.
  • The role of Western nations in enabling corruption through financial systems.
  • Sweden and other Nordic countries: High CPI rankings but significant private-sector corruption.
• Challenges and Future of Anti-Corruption Efforts
  • How democratic erosion fuels corruption.
  • TI’s work with investigative journalists, law enforcement, and corporate entities.
  • The importance of youth engagement and grassroots movements.
• Final Reflections as Daniel’s Mandate Comes to an End
  • Reflections on leading Transparency International through the COVID-19 pandemic, geopolitical crises, and increasing global corruption challenges.
  • The urgent need for renewed energy and passion in the fight against corruption.
  • Encouragement for listeners, especially young people, to engage in anti-corruption efforts and advocacy.

Resources & Links:

• Transparency International Website: www.transparency.org
• Corruption Perceptions Index (CPI) Data: CPI Report
• More on anti-corruption strategies: TI Research

Call to Action: Liked this episode? Share your thoughts with us and join the conversation on fighting corruption. Don’t forget to subscribe to Integrity Insights on your favorite podcast platform and leave a review!

Closing Thought from Daniel:
“All is not lost, but we need much stronger determination and energy in the fight against corruption. I encourage everyone, particularly youth, to educate themselves on this topic and take action where they can. It is central to building a more transparent and just world.”

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In this episode of Integrity Insights, our host Filip Brokes engages in a deep dive with Lana Schwartzman, Head of Regulatory and Compliance at Notabene, into the evolving landscape of cryptocurrency regulation. With over two decades in compliance, including 13 years specializing in crypto, Lana shares her expertise on the implications of the EU's Transfer of Funds Regulation (TFR), the travel rule, and the challenges of compliance in the crypto space. Whether you're in financial services, compliance, or crypto, this episode is packed with insights you should not miss.

Show Notes

Introduction

• Lana Schwartzman’s background and journey into crypto compliance.
• Overview of Notabene and its role in crypto transaction compliance.

Crypto and Money Laundering

• Debunking myths: less than 1% of crypto transactions are illicit.
• Comparisons between crypto and fiat in laundering activities.

Techniques Used for Crypto Money Laundering

• Mixers, tumblers, and chain hopping.
• Privacy coins like Monero.
• Regulatory challenges and enforcement efforts.

The Travel Rule

• Origin and purpose of the Financial Action Task Force’s (FATF) travel rule.
• How the rule prevents illicit transactions before they occur.
• Key milestones: U.S. implementation since 1999 and EU's December 30 deadline.

EU’s Transfer of Funds Regulation (TFR)

• Comprehensive requirements for Crypto Asset Service Providers (CASPs).
• Verification of unhosted wallets and self-declaration methods.
• Role of the European Banking Authority (EBA) in shaping guidelines.

Global Landscape of Crypto Regulation

• FATF report: 89% of jurisdictions implementing travel rule compliance.
• Closing regulatory loopholes across regions.
• Industry-driven pressure for travel rule adoption.

Effectiveness and Future Trends

• Indicators of success: SAR filings and increased enforcement actions.
• Predictions for harmonization of global crypto standards.
• Anticipated regulatory scrutiny and cross-border collaboration.

Resources Mentioned

• Financial Action Task Force (FATF)
• European Commission AML Directives
• ALL AML Infobrief
• Notabene’s EU Deep Dive Course

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In this information-packed episode of Integrity Insights, host Filip Brokes welcomes managing partner of Berlin Risk and ALL AML Jennifer-Hanley Giersch for a comprehensive year-end review of the key developments in Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations for 2024. They cover everything from enforcement actions and regulatory updates to sanctions, cybercrime, and terrorist financing. If you work in compliance, risk management, or financial crime prevention, this episode is a must-listen to prepare for the challenges ahead.

Show Notes

• Introduction
  A look back at the podcast's history and this episode's focus on the regulatory landscape.
• Enforcement Actions
  • Key fines in the U.S., Europe, and beyond.
  • Discussion of significant cases like TD Bank and Commerzbank.
• Regulatory Developments
  • EU AML/CFT Regulation updates, including the AMLA.
  • Expansion of obliged entities to crypto services, luxury goods, professional football clubs and more.
• Sanctions Highlights
  • EU sanctions related to the war in Ukraine.
  • Notable sanctions circumvention cases.
• Terrorist Financing
  • Impacts of the Israel-Palestine conflict on financial regulations.
  • Crypto's role in terrorist funding and OFAC's actions.
• Cybercrime and Financial Crime Nexus
  • EU Digital Operational Resilience Act (DORA) and its implications.
  • Global efforts to combat cybercrime, including a new UN convention.

Resources Mentioned:

• Financial Action Task Force (FATF): www.fatf-gafi.org
• European Commission AML Directives: europa.eu
• UN Draft Cybercrime Convention: UN Cybercrime
• ALL AML Infobrief: https://allaml.eu/en/2024/11/11/der-aktuelle-infobrief-von-all-aml-2/ 

Timestamps

1. [00:00] Introduction
   • Welcome and overview of the episode's focus.
2. [2:00] Enforcement Actions
   • Major fines in the U.S. (TD Bank) and Europe (Commerzbank, Solaris).
   • Key trends in enforcement.
3. [6:25] Regulatory Developments
   • The EU AML Policy Package.
   • Expansion of obliged entities.
   • Impacts of AMLA’s establishment.
4. [16:00] High-Risk Third Countries

• FATF List 
• EU List

1. [20:30] Sanctions Updates
   • Key EU sanctions packages in 2024.
   • Notable cases of sanctions circumvention.
2. [26:00] Terrorist Financing
   • Hamas-related financial networks.
   • Crypto and its role in terrorism funding.
   • New EU and U.S. actions against far-right groups.
3. [32:15] Cybercrime as Financial Crime
   • Connection between cybercrime and money laundering.
   • EU DORA and global cybercrime regulations.

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