08:30 – 09:00

Registration & Coffee

Delegate’s arrival / registration and a chance to grab a pre-event coffee and some nibbles before settling into the day’s busy schedule!

09:00 – 09:10

David Pelled,
CEO MLROs.com

CEO’s Introduction

A quick welcome to MLROs.com Conference Three 2018 from our CEO and an update on the latest forum news and developments.

09:10 – 09:55

 Toni Vitale
Partner, Winckworth Sherwood

Simon Livesey
Partner, Winckworth Sherwood

In this Session Toni Vitali and Simon Livesey (MLRO at Winkworth Sherwood) will examining a few of the key issues coming at us over the hill that we as a community have an opportunity to comment on

1. Law Commission report on the SARs regime (there will be 7 or days left to respond to the consultation on the 26th): The Law Commission is seeking views on a ranged of proposed solutions to remedy the detrimental impact of the SARs regime on the financial sector. The consultation paper has three principal aims: to identify the most pressing problems; to consult on reforming the consent regime; and to generate and consider ideas for long-term reform. Simon Livesey will provide some insight into the proposal in the consultation which include: altering the reporting threshold to require a subjective suspicion and objective supporting grounds (and whether such a change would comply with the provisions of the 4AMLD); altering the Proceeds of Crime Act to contain a statutory requirement that Government produce guidance on the suspicion threshold; issuing statutory guidance to indicate that where a transaction has no UK nexus, this may amount to a reasonable excuse not to make a required or authorised disclosure; and to consider introducing an offence for a commercial organisation to fail to take reasonable measures to ensure its associates reported suspicions of criminal property. Responses to the consultation are invited to be submitted before 5 October 2018.

2. Draft bill on overseas entities owning land in the UK: In August the UK government asked for comments on a draft bill that will require overseas entities owning land in the UK, or intending to own land in the UK, to disclose details of their beneficial owners on a public register. The consultation ends on 17th September and Simon will outline some of the key proposals. The new requirements in the draft Bill will apply to overseas entities. This term is defined widely as ‘a body corporate, partnership or other entity that is a legal person governed by the law of a country or territory outside the UK’. The principal requirement is for an overseas entity to register information about its beneficial owners on the new register, which will be operated by the Registrar of Companies. The intention is that most of the information on the register will be available to members of the public, although certain personal information (including dates of birth and residential addresses) will not be publicly available.

3. Data Protection round up and Horizon scanning: Toni Vitale will look back on the first four months of the new GDPR regime, discuss what the effect of a no Brexit deal will have on the international transfer of data and look forward to new proposed legislation affecting marketing and other aspects of privacy.”

09:55 – 10:40

Neil Whiley
Vice president / principle auditor – Sanctions and Embargoes, Deutsche Bank

The Sanctions and Anti-Money Laundering Act 2018  (SAMLA) – The Sanctions and Anti-Money Laundering Act 2018 received Royal Assent on 23 May 2018. Prior to this Act the UK’s domestic sanctions regimes were confined to terrorism legislation. The Sanctions and Money Laundering Act is therefore a significant piece of legislation and represents a key aspect of the “Brexit legislation” which is required to plug a gap which had previously been filled by EU law. When this Act comes into force, England and Wales will have the power to impose sanctions independently of the international community.

Protecting your Firm against High Risk Geography transactions – This is a hot topic now with France even rushing through legislation to use ‘Blocking Powers’ to try and allow businesses to work with Iran under the Joint Comprehensive Plan of Action signed in 2015.  The Blocking Regulation was of very little use in curtailing US policy on Cuba, and almost certainly will not curtail US policy on Iran. The US financial system is now so important to global and EU businesses that it cannot easily be avoided. Even during the US adherence to the JCPOA, all Western banks were reluctant to do business with Iran, because of the risks posed under US law. This reluctance has now turned into positive dislike.  However, in May 2018, Trump announced the US was withdrawing from the agreement. This coupled with recent meetings of Putin and Trump regarding Crimea and Russian involvement with Syria make these High-Risk Geographies that all MLRO’s need to be responding to at their Firms. We will discuss the current trends and how you can prepare your Firm to manage the risk.

10:40 – 11:00

 Morning Coffee

Selection of teas, coffees, cakes and fresh juice available.

11:00 – 11:45

Meagan Birch
Head of Compliance, Redington

How to build effective board engagement in Compliance

Engagement Skills – How to build effective Board Engagement in your Compliance Programme across your firm – We’ve all been there; too much to do and the Board have Compliance Fatigue….how can you distinguish yourself as a trusted business partner who helps the company achieve it’s goals rather than a business prevention unit image?

11:45 – 12:30

Speaker TBC

Review of FATF UK mutual evaluation

Session Information Pending

12:30 – 13:30

Lunch

Selection of sandwiches, drinks and snacks available.

13:30 – 14:15

Kennedy Talbot QC
Barrister, 33 Chancery Lane

Frozen Money and Breach of Mandate: the MLRO Fights Back

The case law on SARs and disgruntled customers tells a sorry story of rightly suspicious banks and MLROs constrained by tipping off provisions from telling the customer why he cannot access his money. Threats and civil claims by customers can follow. And if they do sue, they can end up being excluded from court in procedures which one judge described earlier this year as Kafkaesque. This session examines these issues through the process of the trial of a bank sued by its customer for failing to act on his instructions.

14:15 – 15:00

David Blunt
Head of the Conduct Specialists Department in Supervision at the FCA

Rulebook Review (July 18) on SMR

It is widely accepted that culture in financial services was a key root cause of the major conduct failings that occurred within the industry in recent history, causing harm to both consumers and markets. This is why the culture and governance of firms is an ongoing priority for the FCA. We want culture in financial services to be transformed so firms and individuals create and maintain cultures that reduce the potential for harm. The extension of the Senior Managers & Certification Regime is directly targeted at the culture of firms and represents another step towards the transformation of culture across financial services. This session will discuss the FCA’s goals for extending the Senior Managers and Certification Regime, and the broader work the FCA is undertaking to speed up the pace of change for cultural transformation in financial services.

15:00 – 15:20

Afternoon Coffee

Selection of teas, coffees, cakes and fresh juice available.

15:20 – 16:05

PANEL SESSION – The Evolution of Regtech – ‘Trends to Watch and Platforms to Know’

Chair: Paul Burleton, Lysis Financial

Dr. George Samakovitis, University of Greenwich 

William Skannerup, Veridankey

Jane Jee, Kompli-Global

Session Information Pending

15:50 – 16:40

Keynote Speaker

Georgina Halford – Hall
CEO, WhistleblowersUK

Mary Inman
Partner, Constantine Cannon

Whistleblowing – a New Paradigm for Whistleblowing -the Way Forward!

With the setup of the new APPG on whistleblowing with Whistleblowers UK acting as the secretariat; Georgina will give us her thoughts on some of the issues likely to surface as the APPG starts to consider how to move this important issue forward in a positive and constructive way.

16:50 – 17:30

Panel Q&A

17:30 – 19:30

Evening Reception & Networking

A fantastic opportunity to decompress with a drink and some food; and network with your peers and the expert speakers of the day, hosted by Winckworth Sherwood.