Tag Archives: money laundering

New Business Models Need New Approaches to IT

Dominos

I have a new post up at CIO of the FutureNew Business Models Need New Approaches to IT. This post brings together a couple of things that I’ve been thinking about recently.

The first is the debate around who will ‘own’ IT in business. Will it be the CIO, the traditional ower of IT? Will it be a different department, such at marketing which has become the big spender on IT in the last few years? Or will be be some new department with a new leader, one that subsumes the current IT department just as the IT department and CIO took over from the Data Centre Manager? All of these options seem short sighted to as they appear to be only addressing the symptoms and not the cause of the problem.

The second thing I’ve been thinking about is anti money-laundering (AML) and counter terrorism-financing (CTF) regulation, since I’ve just done an update to the Technological Considerations of AML/CTF Programs piece published by LexisNexis as part of their Anti-Money Laundering and Financial Crime publication. A side effect of some of the new regulation in this space is that many more companies might be pulled into the regulatory framework – both public and private companies – due to their use of or integration with complimentary currencies. This has interesting implications for enterprise-wide governance models.

My ah-ha moment was when I realised that the debate we’re seeing around the role of the IT department and CIO would be better framed as a question on how IT should be governed in the new digital businesses that are emerging at the moment. Or, as I said in New Business Models Need New Approaches to IT:

Instead of focusing on who the new owner of IT might be, the question we should be asking ourselves is “How does a digital business consume (govern) information technology?” This is an important question, and one that we need to delve into more deeply. (Indeed, I like to keep posts fairly compact but this one post was roughly 2,000 words by the time I was happy that I’ve had covered the issue.)

It’s a long post, but the question is a nuanced one that needs that many words to work through the issues. I recommend that you head over to CIO of the Future and read it, and leave your thoughts in the comments.

Image source: mckinney75402

Bitcoin might make AML/CTF regulation a problem for everyone

I spent a little time over the break thinking about what’s happening with anti money-laundering (AML) and counter terrorism-financing (CTF) regulation, since it had come time to update the Technological Considerations of AML/CTF Programs published by LexisNexis as part of their Anti-Money Laundering and Financial Crime publication. (There’s a blurb for my part embedded below.)

The interesting shift in this version is that growth of AML/CTF regulation for complementary currencies (ie. currencies that are not backed by a government). Organised crime groups are finding all sorts of creative ways to use complementary currencies to launder money, including the creation of bitcoin ‘mixers’ that are intended to improve anonymity for bitcoin transactions.

A side effect of this regulation – which is largely targeted at bitcoin but which is been written in a way to bring all complimentary currencies under regulation – is that the points-based loyalty programme that you were thinking about introducing might actually bring you under the AML/CTF regulator’s watchful eye. Something as ambitious as Facebook Credits definitely would.

This has all sorts of interesting implications for enterprise-wide governance, but that’s a different discussion since it’s well beyond the scope of the Technological Considerations of AML/CTF Programs piece.

If you’re interested then head over to LexisNexis (or we can catch up for a coffee if you like).

Image sourceMike Cauldwell

Technological Considerations of AML/CTF Programs

I had the chance in the last couple of months to review the (very old) chapter Technological Considerations of AML/CTF Programs chapter the I wrote with a couple of colleagues for LexisNexis’s Anti-Money Laundering and Financial Crime publication. The world has changed quite a bit since then so it was more like a recreation than a simple revision.

LexisNexis have kindly made an extract available, which you can find below via a Scribd embed. If you’re interested then head over to LexisNexis (or I suppose we can catch up for a coffee or something).