S3/E5 Rethinking AML/CTF Effectiveness, with David Lewis

Speaker 1 Welcome to the Financial Integrity Hub podcast. At the Financial Integrity Hub, we lead research into the legal and governance frameworks that underpin effective responses to money laundering, terrorism financing and proliferation financing. This podcast is proudly sponsored by Arctic Intelligence, a multi award-winning Regtech firm specialising in financial crime risk orders and compliance software. Trusted by regulated businesses in over 25 countries, Arctic Intelligence delivers highly configurable cloud based AM, LCTF and financial crime risk assessment platforms and content that help organisations better identify, assess, mitigate and manage financial crime risks. Speaker 2 Welcome to the financial integrity. Speaker 3 Help Podcast. Speaker 2 The show with hot questions and even hotter insights at the intersection of law and financial crime. I'm your host, Doctor Hannah Harris, and today we're joined by David Lewis. David is the former executive secretary of the Financial Action. Speaker 3 Task Force. Speaker 2 And a leading voice on anti money laundering, counterterrorist financing and illicit finance policy and practice. At the FATF, David helped shape the global standards that governments and financial institutions rely on to combat financial crime and protect economic security. Informed by previous roles at the UK Series Organised Crime Agency and the UK Treasury, David now works in private practice advising on complex financial crime risks. In our conversation today, we discussed the importance of shifting the focus of AM LCTF evaluation towards a more practically grounded assessment of risk and meaningful discussion of impact, harm and effectiveness. David highlights the need to advance intelligence sharing between stakeholders and breakdown historic barriers that are often grounded in fear of punitive enforcement action or reputational risk. We also explore the importance of framing AML, CTF systems and the regime as aligned with a wider culture of sustainable business practice. The conversation is an optimistic 1, reflecting that many of the critiques levelled at the status quo approach can in fact be reframed as a starting point towards reinvention, with the objective of not only stemming the illicit. Speaker 3 Flow of. Speaker 2 Funds, but also, in doing so, undermining the capacity of criminal actors to generate. Speaker 3 Reward from the criminal. Speaker 2 Acts that cause extensive harm to society, economy, and the environment, with a disproportionate impact on vulnerable communities. This was a really engaging conversation and I can't wait to share it with you. But before we get started, Please remember if you haven't already, to like and subscribe to the Financial Integrity Hub podcast on Spotify and YouTube, and follow the Financial Integrity Hub on LinkedIn to stay up to date on the latest insights and upcoming events. Speaker 3 Welcome, David. It's great to have you here today on the Financial Integrity Hub. Speaker 2 Podcast I. Speaker 3 Would love to jump straight in because you have such a wealth of knowledge and expertise in this space and I know that our listeners are keen to get as much out of that as possible. So I was wondering if you could start by giving us a little bit of your back story where your interest in financial crime originates and how you got to where you are today? Speaker 4 Sure. Hi, Hannah. So I first encountered financial crime when I was at the Serious Organised Crime Agency in the UK, now the National Crime Agency. I was running a a branch of former police, customs officers and and and Spooks responsible for sharing intelligence with the private sector to disrupt organised crime and and target Harden. And that involved things like boiler rooms inside a dealing, sharing stolen credit card data from from the dark web with the banks, letting the banks know if a bank robbery was being planned, or letting a supermarket know if their coffee bags were being used to import drugs from Afghanistan. So it was pretty wide-ranging. And I got to know the FIU at that point because that was in the same organization and wasn't in it. And I decided I needed to stay as far away from them as possible because they needed to receive everything in a suspicious transaction report format, which then never got to see the light of day and I didn't get to use. So I thought it was better if I had my own relationships with the banks where I would deal with the data more, more freely. So that was my kind of starting point with with Financial Prime. Speaker 3 I think that's such a fascinating point that I'm already wanting to go off scripts or advanced apologies. But this whole idea around the different mechanisms through which regulatory agencies and enforcement bodies interact with institutions and business around financial crime. There are different approaches, different theories and typologies around what works there. And as you point out, the kind of distinction between a more traditional law enforcement approach and relationship dynamic versus the kind of traditional financial intelligence unit approach and the reporting and the secrecy and kind of protections around that dynamic. How do you see that having evolved since you started back then? Maybe what have you observed in terms of the evolution both of financial crime threats but also the kind of response to those in the regulatory space? Speaker 4 Sure. Maybe going back a little bit, when, when we set up Serious Organised Crime Agency, we had this broad information gateway, information sharing gateway, which basically allowed us to share any information we had for any of our purposes as an organization and to receive any information and use it for, for the same purpose. And, and that was a fairly novel piece of legislation. But what I realized was when I was dealing with the banks, I, I would often end up dealing with the head of security rather than the compliance officer. And the two didn't really speak to each other. And when I ended up speaking to the compliance officer, they would say, well, we speak to the FIU and we submit information in, in STRS and, and we'd prefer to go down that route. And I would say, well, what if I want some, I need to get some information from you urgently. They would say, well, you need to put in a production order. And so it was, it was kind of kind of frustrating in those early days. And I think that that's evolved massively in terms of the kind of response to financial prime. We're now in a world where largely because the banks have been hit with big fines, they've hired lots of former police officers and government folk who you can call up now and who are willing to find a way of getting you the information that you need. And often the reluctance is on the other side. And they're kind of the authorities going well, I'm not sure I can receive that or and you're in a situation where the banks are kind of banging on the door saying let us help you. And the public sector are often not as well resources they should be and they're not confident sometimes to deal with that information. So I see that as one of the key evolutions. But in terms of how financial crime has changed, I would say a lot and at the same time not much. So you hear a lot about these days crypto and artificial intelligence and the way fraud has been industrialized. All of those things are true. But fraud was always massive. You know, the high volume, low value stuff from Nigeria elsewhere and the public sector. The police were always under resourced. It was always less of a priority and the traditional ways of money laundering through cash, through the informal remittance sector, through trade based money laundering, I, I think of probably where most money still laundered and which, you know, we, we don't do enough or don't focus enough on. So we, when it comes to money laundering, we like the kind of new shiny thing. We like to talk about Bitcoin and so on and maybe gloss over how that's a lot more transparent than cash and easier to follow than than cash. You don't need a police officer in a car following a crook with a bag full of cash. You can sit down on your desk and, and, and follow the blockchain. So, so that's why I say it's changed a lot, but also not much. The international response has kind of evolved. FATF is now focused a lot more on fraud than it has in the past. It was the first standard setter in any area to call for the regulation of virtual assets and virtual assets service providers. The, you know, that was also under pressure from the G20 finance ministers, central bank governors who I think were concerned mostly about Libra at the time and maybe losing sovereignty and control of their own currencies. But we saw, you know, cryptos being used for terrorist financing for organized crime wasn't on a massive level, but it was starting to happen. So, So that was 1 area, I think, in which the international response has been pretty good. It's taken a while, It's still taking a while for the kind of industry and regulators to catch up with that. But I think, you know, if you're reading about financial crime these days, you're normally reading about fraud or crypto or, or or the use of technology by by criminals for committing fraud on the crimes. Speaker 3 Yeah, I I think that makes sense. And I mean, it is human nature to focus on the new shiny thing, right? But I mean, doesn't make for as good a cinema as chasing down a, a robber with a bag of cash. And it's, I don't know, almost nostalgic for me to hear that that some of the high apologies are still being used very heavily by criminals and that we have actually been encountering some of the same problems even with these newer forms of crime since we started focusing on these issues. I guess one for me that came up a lot during the financial Integrity Hub week, which you were at as well, was this the role of trade based money laundering. And when you mentioned the FATFI know also that they've focused in on that as the kind of third typology and their framework for understanding financial crime threats. I wonder if maybe you can speak a little bit more to the role of the FATF in the financial crime space and in the approach that governments and industry are taking in response, given your background and having previously been secretary for the FATF at some point. Speaker 4 So the FATF was formed in 1989 by the G7 really to go after the money from the drugs cartels, part of the war on drugs. There are different stories about how and why the underlying reasons for it, but it quickly grew to today we have 40 countries, including the European Commission, the Golf Cooperation Council, and then a global network of nine regional style bodies, which includes in your area, the Asia Pacific Group, that have responsibility for assessing countries in their own region. And the FATF essentially does three things. It understands how money is laundered and how terrorists raise and access funds through working with police forces in member countries. It develops standards to respond to those threats. Those are standards for governments, for national authorities, police, regulators and for the private sector. And then it assesses countries against those standards. Those countries that perform the worst get put on a list and that pushes up the price of due diligence, cost of due diligence. It reduces foreign direct investment. It harms the reputation of a country and it really puts pressure on them to fix things that are broken or not working as well as they as well as they should do. So that's the kind of bread and butter of of what FAFF does. Speaker 3 Yeah. And I think that it's quite well established now as a standard setting body. And also as you mentioned, these reviews and assessments are kind of a central focus for countries involved in the process. I know every time that there is a review cycle coming around, there's a lot of discussion both from industry and from policy makers around are we going to be found to be compliant? Are we not? Where are the weaknesses? Where are the strengths? One of the things I'm interested in with that dynamic, which I think has been extremely powerful in, in shaping legislation in a range of jurisdictions and coming from a anti corruption background with foreign bribery, I see some similarities in the way that the normalization has occurred across jurisdictions, which fills a lot of gaps regulatorily I think is probably a really good thing. But with the FATF standards and the kind of approach to assessment, in the past, there's been some criticism around kind of technical compliance with the standards being the focus more so than the actual underlying purpose, which is to combat financial crime effectively or to stop financial crime occurring as frequently as it does because of the harms related to that crime. I wonder if you have any thoughts on whether there's been a meaningful shift in that mentality or approach, both within the FATF but also in response to this problem more broadly. Do you think there is a shift? What might still need to change? Do you think a change is necessary in that regard? Speaker 4 Yes, there has been a shift. It started for the FATF back in 2013. They were the first standard setter again in any area that recognised it wasn't enough to assess whether countries just have in place the right laws and regulations and institutions, but whether they were using those effectively and whether any of that was having any impact. So it developed a methodology which is largely subjective around, you know, how do you how do you assess impact? And lots of people critique that and rightly and it needs to continue to evolve, but I think it's the right way forward. And, and it's led to a change of emphasis in the way that countries are assessed. And, and it's and it's now leading to a change of emphasis in the way that supervisors and, you know, regulators are starting to do their business is not as quick as the banks in particular would like. You know, they see the need for a focus on effectiveness. If you look at the Wolfsburg group and they're and they put out really useful statements on effectiveness. And so we're in the situation where Fat F recognizes it needs to be done, the banks recognize it needs to get there, but the system is trying to come together to make it happen and it's difficult. We've now had every country in the world from a fat F perspective assessed for effectiveness. We've had one complete round of evaluations and the results were not, not good. And it kind of led to a lot of criticism of fat F You know, you have high levels of technical compliance around the world, but low levels of effectiveness. So people say, well, how can you be compliant and ineffective? And but the reality is most of the countries that were listed by the FATF in the last round were not listed because they were technically non compliant, but because they were ineffective. And I did a looked across the country results a couple of years back and it was noticeable that out of 200 odd countries, five were only five were largely or fully compliant with all 40 FATF recommendations. None of them were G20 countries. And at the same time, three of those five were on the FATF Gray list. So you could be completely compliant and completely ineffective at the same time, which says a lot about the system, but also about how the FATF and others are recognizing that the system needs to change. And you can't just jump from one to the other. You have to maintain a focus on technical compliance and ensure the right laws are there, you know, ensure that money laundering, terrorist finance is properly criminalized. But you also have to ensure that the use of this system we've created is focused on the right on the right things. So I think we're getting there. It's started. It's irreversible, but it's it's slow. It takes a long time for these things to filter through and it's starting to happen. Speaker 2 Do you have? Speaker 3 Any examples that stand out to you of it happening that particularly that transition from perhaps a particular standard and it's implementation and subsequent effectiveness or are we just too early and trying to put all of these different aspects of data together to to evaluate that? Speaker 4 Well, the the initial evaluations in the new round that the FATF is undertaking show a higher level of effectiveness. You know countries like Latvia for example that performed very badly last time and now coming out on on top. They've completely changed the way they operate, take a risk based approach, an intelligence based approach. They operate internationally across borders very effectively. There are still challenges, but you can see the direction of change there. And there are other, other, other examples like that. I, I think it's where it becomes difficult is critics, including myself, will say, well, the scale of money laundering is still growing, isn't it? So on the one hand, you can say, well, you know, financial intelligence is being used more. The information that banks collect is being put to greater use. There are more investigations, there are more prosecutions, there's more disruption. All of that is great. But when the scale of money laundering is still growing, you're kind of saying, well, is this working? And I think that's, it's a, it's, it's a useful, it's useful to hold our feet to the fire. But it's, it's a dynamic that has to be managed. You want to continue to improve the system, but at the same time recognize the scale of the challenge it faces and and maybe this is not the only approach, maybe there are other approaches. Speaker 3 I guess that's a really good point too, right. We're looking at this particular regime when if from an enforcement deterrence lens and to some degree from a compliance lens. And we can talk maybe a little bit about more the industry side now that you've moved into that kind of advisory space shortly. But from kind of one end of the spectrum. But then it occurs to also, as you mentioned, the kind of growing scale of money laundering that there is a preventive side of the spectrum as well that might be more aligned with a lens of harm or? Targeting what is generating the need for in the 1st place money laundering need being the kind of organized criminal need or what's actually driving this expansion. And which brings me back then to your origin story and, and the relation and the FATFS to some degree their core relationship to organized crime. Originally it was more of an observation, but I think that you're one of the first people I've talked to who's raised this point about maybe this particular framework is only one part of the wider equation when we're thinking about financial crime. Speaker 4 Yeah, and I think people forget that we created money laundering as an offence in order to take the profit out of crime. It's so when people say, well, we're losing the battle against money laundering, we always will. Maybe that's a bit of a defeated defeatist attitude. But while there is crime, there will be money laundering and people don't say let's scrap the police because there's crime on the streets. You know, the the purpose of the money laundering offence is to give the authorities the tools they need and to gather the collaboration of the private sector to tackle those the harms caused by the underlying predicate offences, whether it's drugs or guns or fraud. And, and I think we've lost sight of that, including, I might say, you know, the FATF, you know, if you ask dozen people why we do what we do, you might get a dozen answers and the best people say, well, all of them apply. But when you're trying to do everything, it's understandable if you're not so effective. And I think that's, that's one of the challenges. Your group is called the Financial Integrity Hub. Is that the purpose of the regime? Is it financial integrity? Is it reducing harm? Is it protecting the financial system? All of those things are quite different, a bit different, maybe require different responses, and so I think we need to think about it more holistically. Speaker 3 Yeah, I agree. And then the challenge with thinking about something holistically, as you point out, is that doesn't necessarily mean that a single organization or entity can deal with the problem holistically. Maybe it's about kind of not siloing, but matching up the right institutional mechanisms or the right approaches with that part of the problem. And this question of effectiveness also always brings up for me the issue of measurement and occurs to me if at the FATF you have 12 different, for example, ideas about what the purpose is, you probably also have 12 different answers to the question of whether you're being effective in achieving that purpose. So that's also probably quite complicated. I wonder how industry is viewing this and what your thoughts are on the industry perspective, both in terms of compliance but also maybe if there is a interest in or a convergence around the objectives of the banks and other industry players when responding to financial crime. Speaker 4 I think that there is within pockets and certainly the larger financial institutions. So we mentioned the Wolfsburg Group earlier on. They get it. They've invested heavily in their own FIUS. They're no longer being just reactive. They're proactively looking for dirty money in their organizations and they're actively looking to be part of public private partnerships and to share information. But that's only really working well with a small number of larger global financial institutions. And when you get down to the second tier, the mid tier, the low tier banks, the long tail of smaller banks, they have a much less developed understanding of risk. And their behaviour is all too often driven by fear of fines, then by the possibility then my organization might be used for fuelling crime or funding terrorism. And so when I I speak to them about their enterprise wide risk assessments, you you're often looking at something that talks about what? We've got legal risk, we've got reputational risks, we've got regulatory risk. I'm saying, yeah, but what is the risk of your organization being used for this crime? And, you know, given the products you offer and the countries you operate in, have you thought about, you know, what criminals are doing and how you might be used as part of that scheme? And they often don't look at it from that perspective. And I think that that same critique could be applied to the whole financial crime system. You know, the behaviour is outside of pockets of good practice, largely driven by fear, a country, fear of being listed, a bank, fear of being fined. And I think that often drives the wrong kind of behaviours. It at least it leads to some activity, but often it's short term and you see peaks of activity around, you know, the announcement or head of announcement refine or a country being listed. And so people are still working out whether this is something they really ought to care about or they just care about because they're required to. Speaker 3 Yeah, I and again there are mirrors in the corruption anti bribery space with that as well. And it also occurs to me when you were talking about particular organizations and kind of best practice of, of being proactive and assessing risk, not only from a risk of enforcement and, and fines perspective, but from a actual risk of the in some ways participating in the underlying predicate offence or in some way facilitating it. I think that's such a fascinating and potentially really powerful reframe that ties into your earlier comments slash critique that maybe at the higher institutional level, we also have lost sight a little bit of the whole purpose and point of this, which was to target the profits of underlying criminal activity to try and reduce underlying criminal activity which primarily is engaged in for profits. So it's nice to hear, I guess, although maybe only in pockets that there is an opportunity for that to become the norm. I wonder if you have maybe any insight into what makes an organization, particularly in industry, more likely to adopt that approach. I guess good advice is maybe 1 answer to that question, but what do you see as the kind of way out of this fear based reactive approach for institutions? Speaker 4 I think it's the, the difference between short term profit making and long term sustainable business growth. You know, you could say the same about climate finance or you know, other areas. It's about understanding from a business point of view. Of course, it makes sense to know who your customers are because you want to be able to serve them better. And why wouldn't you report suspicious activity? And it's got to be the in the interest of your business to protect it in the long term from being used for these nefarious threats. So it's it's if you can, if you can develop a culture which has top down support and often that top down support is missing in countries, not just within institutions, but at the political level. You know, governments are in power for a few years and so they need results quickly and, and so long term strategies like that sometimes get lost and their focus is very temporary on, on things like this. You know, it'll revolve around a, a summit or something and then then they'll have to move on. So these are all the challenges that exist when you talk about moving the mindset away from short term profit making to long term sustainable growth for businesses. But I think that it, it, it takes a cultural change and not a change in laws and regulations to get there. And I think it's, you know, businesses are starting to get it, but it's, it's a hard thing to do when you know, particularly if you're owned by shareholders who who want to return on the quarter. So and regulators need to play their part in that. Largely bank behaviour is driven by regulatory behaviour. Regulators are not there yet. They still punish firms for the wrong things. They take a 0 tolerance approach. Sometimes we want, I'll get slammed for saying this, we want dirty money in the formal financial sector when we want banks on board. We're trying to spot it and helping us deal with it. We can't keep it out. You can't keep risk out of banking. If you do, you'd have to, if you wanted to do that, you'd have to shut down the banks. And if you didn't have The Dirty money, if you don't have The Dirty money flowing through the banks, well, it's out of sight. It's going through informal sectors that you are much, much more difficult to deal with. So financial inclusion and tackling dirty money together, they, they're not something to be balanced. So you have all these perceptions of competing priorities, but often they're working towards the same aim and that's why cultural change is so important. Speaker 3 And I really love that point too, because in some of our other conversations on the podcast this year, we've kind of talked about this dichotomy between de risking and financial inclusion, for example. And it sounds like in our conversation, what you could be saying and correct me if I'm wrong here, but is that there is actually an alignment between, if we reframe risk assessment, there is an alignment between that form of approach to risk and financial inclusion, which I think is an optimistic perspective. Speaker 4 Yeah. And I think we'll get there, but you know, it's tough on the banks when they have to make decisions about continuing to serve customers. And, you know, on the one hand, the thought that maybe the money flowing through their bank might be going to fund al Shabaab in Somalia or that the response from regulators might be disproportionate. And and so they'd rather not take the risk and particularly if the, if the banking activity they're undertaking is low margin, then you can see why they say, well, on balance, do we really need to be doing this business? And that affects more often than not, vulnerable sectors, vulnerable communities and people. And so you end up having conversations about should there be a legal requirement to a bank account and actually manage the risk of that. It's a complex error. Speaker 3 Yeah. And I think tied to that your your point, which you made bravely, but I'm happy to back you up on. And I think that the research really supports this and has for a long time in all spaces of crime is that you do want to be able to see it. And sometimes that's scary and sometimes that's unpleasant, but it's better to have it visible than not because it's not magically not there just because you can't see it, Right. Yeah. And I guess I hadn't really put that together with the way regulatory or particularly enforcement culture could impact that, the willingness to take that approach, particularly for the private sector. Any other thoughts on that? I'm also thinking in the context of reform. And I had a question here where I was only going to give you a single reform that you thought would make the global AML, CTF kind of framework more effective or enhance financial integrity. And maybe I should allow you a bit more wiggle room with a single reform. And you've also already said it's not just about regulation, but I wonder if or if you can humour me on that. Speaker 4 Question. I think my way of getting around this question is to give you a very broad answer. You know, there are increasing conversations around what is Plan B thinking the unthinkable. You know, groups of people coming together have been doing this for a long time, going well. If the current approach isn't working as well as we think it should work, isn't justifying the efforts going in to prevent money laundering and the cost of that, what is the alternative and how do we get from where we are now to that point? Because we've created a compliance industrial complex that everyone has invested in and it's very difficult to change. You know, it's, and, and the FHF is part of that, but only part of it. And so it's not just about steering a, an oil tanker. It's, it's, it's, it's much more difficult than that in some respects. So I think you need to step back. And it's what we were saying earlier, if we can find time to have a conversation, to reflect on, what are we seeking to achieve, Is there sufficient evidence when you put it all together, the current approach is working. And if there isn't, then are we willing to consider fundamental change? And then what might that look like? And I don't want to jump to what that might look like, but there are suggestions out there, including from some of the academics in your part of the world. We need a system approach and we also need an operational approach. And both of those things need to work together and often they don't. We have a system approach that works quite, you know, in, in parallel with, but often doesn't touch the operation approach. You know, we develop risk assessments that are put on the shelf and then don't inform the the policies and the strategies that the country takes. We develop wrist apologies that doesn't then inform the priorities of law enforcement who are out there deciding who they should chase today. So they need to be aligned the system approach and the operational approach. You know, I'd like to see more international task forces focused on a list of the top ten money launderers globally, if that's possible. Why don't we do that into that? In the same way we pulled our resources to go after the funding of ISIS quite successfully, why don't we do the same with the funding of of crime? You know, you go back 10 years, the Italian mafia, the Andrew Geta, we're turning over more money a year than McDonald's and Deutsche Bank put together. And we know who the money launderers are that are dealing with that. But people say, well, that's an Italian problem. Well, no, it's not. It's a global problem. So, so there needs to be a system approach, there needs to be an operation approach that needs to be aligned. And it's not just about a risk based approach by regulators and firms, but an intelligence LED approach. So we're not just looking at topologies. We have to be brave enough to share information and intelligence and that's difficult sometimes. You know, when I was in law enforcement and in the Treasury afterwards, you know, when you have access to intelligence that shows who's having conversations about money launderers and that includes someone at a bank that you're talking to. You're therefore cautious about bringing that bank into a partnership because you know that there's at least one guy in that bank, which might be a bank with 100,000 people in it who who is having a conversation they shouldn't be having. So you need to find a way of having bringing everyone together, being having a more inclusive approach while managing that that risk. And it's difficult, but it's starting to happen. Speaker 3 Yeah. And I think it's the hope for the financial integrity up to some degree that we can be a neutral collaborative space for these types of conversations. There were at least a jumping off point for these types of conversations, whether it's through something like financial Integrity week or or some other kind of less publicized areas of our collaboration and work. But it really does seem like the more opportunities we can create for, I like your term intelligence sharing, right? So not just the information, but actually the insights that have come from that information or that have come from the process of gathering it that can provide new perspective on what's working and what isn't. It sounds good. I think there's a lot, as you point out some of them of kind of challenges or hurdles to overcome. Given that and given that, I try and always avoid ending on a depressing, which is not always possible. But I think for our conversation is what gives you optimism about the future of global financial integrity efforts or or the global attempts to combat financial crime? Are there any examples that have been inspired you in your work or more recently? Speaker 4 Well, I would think generally, you know, 20 years ago there was a very poor understanding of financial crime, very little political backing, not enough people working in the banks who understood it. The public sector did most of the work. Now, as I mentioned earlier, you know, the sheer weight of people across the public and the private sector who understand financial crime, who get that it causes harm that we're talking about real people, real harm on, on citizens, on economies, on, on the planet. You, you meet more of those people, whether you're talking to a bank or a law enforcement agency or an FIU or regulator than any other type of people. And, and, and politicians are now force getting forced to have that conversation as well. There are never ending conferences and summits about this stuff. There's one in Paris the other day. No money for terror. You know, you can get grow a bit tired of these events, but it's better than not having them. The conversations happening. People want to have it. People want stuff to happen and they're informed enough to be critical about the current system. And so you can sit back and say, well that criticism means it's nothing, nothings working or it's not working as well as it should. Or you can sit back and say that's fantastic. How do we harness all of this, this energy, this knowledge across diverse sectors, including academia, including civil society, to do a better job? And I'd love to see the the FATF become, you know, an FATF meeting becoming a meeting not just of governments, but of civil society, of the private sector, of academia, where, you know, thoughts can be exchanged. And we don't just have bilateral binary conversations, you know, events where the private sector talks to government. But this is an ongoing dialogue and everyone's in the same tent working together and you know, so their recognition, the weight of people, their recognition of the challenge, the recognition of the need for change, the evolution of public private partnerships and the ship, the potential of technology. But dealing with all of that because we've got a system that was designed around putting in a saw when you see a suspicious transaction, well, the volume of transactions, the speed in which transactions are done just doesn't make that possible anymore. We need to use technology and we can use it in so many different ways in the way in the same way criminals are. So I think there are so many reasons for optimism and with the help of, you know, organizations like their financial integrity out there are ways in which these people come can come together that didn't exist before. Speaker 3 A fantastic and very optimistic outlook, which has made me want to talk to you for another hour, but I will resist. Thank you so much for joining us. I really appreciate your time and I know our listeners will love hearing all of your insights. Thanks again. Speaker 1 The Financial Integrity Hubs research is at the cutting edge of understanding and tackling illicit finance threats, providing the international community with essential knowledge, tools, and insights to make a real impact. If you want to stay ahead in the world of financial integrity, make sure to follow us on LinkedIn and on Spotify. We're always sharing the latest updates and events, breaking news, and research insights. Join us and become part of a global community committed to fighting financial crime and protecting our economies and societies from illicit finance threats. A huge thank you to Doctor Doran Goldbasch for his academic leadership, to Creative Beast for the editing, to Arctic Intelligence for their support in bringing this podcast to life, to Doctor Craig Cameron, and to Doctor Hannah Harris for hosting. Thank you for listening. We will return with further conversations shaping the future of financial integrity.