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The purpose of this paper is twofold. Firstly, it highlights areas of disconnect between how the financial services sector in the UK approaches the requirement to evidence source of wealth when conducting customer due diligence; the requirements of the UK’s laws and regulations in relation to evidence source of wealth; and the expectations of the Financial Conduct Authority (FCA) in this regard. It then proposes an alternative approach to evidencing source of wealth.

Semi-structured interviews have been carried out among compliance professionals in UK financial services.

This paper provides rare insight into the anti-money laundering arrangements of UK banks, an area that has not yet been widely researched in the academic literature. It highlights a lack of legal certainty in the UK’s laws and regulation around anti-money laundering and argues that the expectations of the FCA exceed both the letter and the spirit of the laws. It suggests that mixed messages disseminated by the FCA have incentivised banks to shift their focus from financial crime risk (i.e. preventing money laundering and terrorist financing, etc.) towards regulatory risk (i.e. the risk of falling foul of regulatory expectations) and proposes a change to the law and regulatory guidance to enhance the level of legal certainty needed for the law to be effective.

The paper makes suggestions for a more practical and risk-based approach to anti-money laundering compliance and for a much-needed change in the law.

It provides unique insight into the due diligence challenges of financial services firms and argues for the FCA to propagate a more risk-based approach to enhanced due diligence.

This paper aims to show how financial services firms determine whether customer transactions or behaviours meet the threshold for suspicious activity reporting mandated by the Terrorism Act 2000 and the Proceeds of Crime Act 2002, and how suspicious activity reporting is executed in practice.

Semi-structured interviews have been carried out among compliance professionals in UK financial services.

Two issues related to suspicious activity reporting have been identified. Firstly, a widespread misunderstanding about the tipping-off offence under s. 333 Proceeds of Crime Act 2002 has been identified, which appears to be a root cause for poor quality as well as over-reporting of suspicious activity. Secondly, issues related to the notice and moratorium periods used by the UK’s National Crime Agency appear to deter reporting of suspicious activity related to live transactions.

The paper makes suggestions for changes financial services firms and the UK’s National Crime Agency can make to improve the effectiveness of suspicious activity reporting.

The paper provides valuable insights which can be used to limit the flow of criminal funds, improve the quality of suspicious activity reporting and enhance the effectiveness of law enforcement agencies.

This paper aims to propose a new research agenda that integrates the often-overlooked insights and experiences of compliance professionals into anti-money laundering (AML) policy formulation and academic research. It seeks to highlight the importance of a bottom-up approach in developing AML strategies that are not only theoretically robust but also practically effective and grounded in real-world application.

Using a comprehensive literature review and theoretical analysis, this study outlines six broad research focus areas. These areas are explored through the lens of existing theoretical frameworks that underscore the significance of practical insights, interdisciplinary collaboration and adaptive policymaking in enhancing AML efforts.

This paper highlights a significant gap in current AML research and policymaking, namely, the underrepresentation of compliance professionals’ perspectives. It argues that integrating these frontline insights can lead to more nuanced and effective approach to AML.

Adopting the proposed research agenda could significantly enhance the practical applicability of AML policies, leading to more effective prevention and detection of financial crimes. It encourages the development of support systems for compliance professionals, fostering a workforce that is both competent and resilient.

By promoting a more inclusive and practice-based approach to AML policymaking, this paper advocates for a societal shift in how money laundering is tackled.

This paper contributes to the AML discourse by proposing a shift towards a more inclusive research and policymaking paradigm that values the contributions of compliance professionals. It extends the existing literature by suggesting a comprehensive framework for bridging these divides, thereby offering a novel perspective on enhancing the effectiveness of AML strategies.

The purpose of this study was to investigate the perception of trade-based money laundering in Letters of Credit (“L/C”) transactions among trade finance practitioners in the UK banking sector and to compare it to the perception of the same risk by the Financial Conduct Authority (“FCA”), the regulator of the UK’s banking sector.

A survey was used to carry out research among financial services professionals engaged in trade finance in the UK.

This paper contributes to the existing literature in a number of ways. First, it investigates the perception of trade-based money laundering risk from the perspective of financial services professionals, which has not previously been done. Second, it argues that the perception of trade-based money laundering in financial services is overly focussed on placement, layering and integration, and that the full extent of the offence under the Proceeds of Crime Act 2002 is less well known. It further found that financial services firms need to improve their understanding of the nature of trade-based money laundering under UK law.

This study argues that the financial services sector’s perception of trade-based money laundering risk in trade finance is underdeveloped and makes suggestions on how to improve it.

It provided unique insight into the perception of trade-based money laundering risk among financial services professionals.

The purpose of this paper is two-fold. First, it highlights areas of disconnect between how the financial services sector in the UK approaches the management of politically exposed persons (PEPs) risk; the requirements of the UK’s laws and regulations in relation to PEPs; and the expectations of the Financial Conduct Authority (FCA) in this regard. It then proposes an alternative approach to the risk-management of PEPs.

Semi-structured interviews have been carried out among compliance professionals in UK financial services.

This paper provides rare insight into the anti-money laundering (AML) arrangements of UK banks, an area that has not yet been widely researched in the academic literature. It argues that the expectations of the FCA exceed both the letter and the spirit of the UK’s laws and regulation around AML by emphasising an administrative approach over a qualitative/analytical approach to risk-management. It further suggests that mixed messages disseminated by the FCA have incentivised banks to shift their focus from financial crime risk (i.e. preventing money laundering and terrorist financing, etc.) towards regulatory risk (i.e. the risk of falling foul of regulatory expectations).

The paper makes suggestions for a more relationship-centric approach to PEP risk-management.

It provides unique insight into PEP risk-management in financial services, and argues for the FCA to propagate a more relationship-centric approach to PEP risk-management.

The case’s learning objectives to work on can vary according to the topic selected by the teacher. This case has been put forward with a particular interest in corporate strategy issues, specifically, on the joint management of businesses (in this case, academic programs). Therefore, students are expected to be able to understand the managerial dilemma on centralization and decentralization; recognize the peculiarities of a shared services center (SSC); and decide on which services to centralize in an SSC.

Centralizing or not centralizing is a frequent managerial dilemma. This is a challenge faced not only by business managers but also by corporate level areas responsible for jointly managing various businesses. Resources and capabilities allocation is an essential process for strategy execution, specifically in corporate strategy that must answer the question: How to jointly manage businesses? Sharing services is a collaborative strategy which aims to increase efficiency by centralizing some processes related to this joint business management. Mario, Dean of the Escuela de Administración in Medellín, Colombia, intends to optimize the school resource allocation processes so that there is more equitable support between the different academic programs. For this, he has thought of creating an SSC as it is a practice that he has seen in prominent companies in the city. His idea is to start operating the SSC in early 2018; however, the particular character of a management school leads him to ask himself: What to centralize and what not to centralize?

This case of decision (Ellet, 2007; Sánchez et al., 2013) can be used to promote student learning of strategy courses both at advanced undergraduate levels and in graduate programs. Likewise, it can be used in workshops with executives and administrative personnel of companies that face the centralize–decentralize dilemma. These types of topics are the subject of study by both corporate strategy theorists who address the question of how to jointly manage business (Menz et al., 2015; Michael Porter, 1987) and consultants (Deloitte, 2012). It is desirable, although not mandatory, that students have some knowledge or experience in strategic issues and challenges associated with the administration of companies made up of various businesses (multi-business firms).

Teaching Notes are available for educators only.

CSS 11: Strategy.

Comprender el dilema gerencial sobre la centralización y la descentralización. Reconocer las particularidades de un centro de servicios compartidos 3. Decidir qué procesos centralizar en un centro de servicios compartidos;

Centralizar o no centralizar es un dilema gerencial frecuente. Este es un reto que se aborda no solo desde la gerencia sino desde distintas áreas de nivel corporativo con responsabilidad de administrar conjuntamente varios negocios. La asignación de recursos y capacidades es un proceso fundamental para la ejecución de la estrategia, en particular la estrategia corporativa que debe responder a la pregunta ¿Cómo administrar conjuntamente los negocios? Los servicios compartidos son una estrategia colaborativa que tiene como propósito el incremento de la eficiencia por la centralización de algunos procesos asociados a la administración conjunta de varias unidades de negocio. Mario, Decano de la Escuela de Administración de la Universidad Empresarial en Medellín, Colombia, se propone optimizar la asignación de recursos de la escuela de manera que haya un apoyo más equitativo entre los diferentes programas académicos. Para ello ha pensado crear un centro de servicios compartidos (CSC) pues es una práctica que ha visto en empresas destacadas de la ciudad. Su idea es empezar a operar el CSC a inicios de 2018, sin embargo, el carácter particular de una escuela de administración lo lleva a preguntarse: Qué centralizar y qué no centralizar.

Este caso de decisión (Ellet, 2007; Sánchez et al., 2013) puede ser utilizado para promover el aprendizaje de estudiantes de cursos de estrategia tanto en niveles avanzados de pregrado como en programas de posgrado. Así mismo, se puede utilizar en talleres con ejecutivos y personal administrativo de empresas que enfrentan el dilema centralizar-descentralizar. Este tipo de temas son objeto de estudio tanto de los teóricos de la estrategia corporativa que se ocupa de la pregunta sobre cómo administrar conjuntamente los negocios (Menz et al., 2015; Michael Porter, 1987) y consultores (Deloitte, 2012). Es deseable, aunque no es obligatorio, que los estudiantes tengan algún conocimiento o experiencia en temas de estrategia y retos asociados a la administración de empresas conformadas por varios negocios (empresas multinegocios).

Teaching Notes are available for educators only.

CSS: 11: Strategy.

Organizational culture plays a central role when dealing with the issue of digital business transformation (DBT). Managers handling a DBT and involved in digital strateging are expected to modify the organizational culture of firms to make it more fitting with the paradigm of digital economy and having more chance of success. Thus, it is noteworthy to inspect the role they can have over DBTs. Accordingly, the purpose of this paper is to investigate the behavior that managers assume when they approach DBTs by investigating whether they act as mentors/facilitators or entrepreneurs/innovators, as coordinators or decision makers.

To achieve the above purpose, ten case studies about manufacturing firms have been selected. Case studies, retrieved by the Digital Innovation Observatories of the School of Management of the Politecnico di Milano, are studied and analyzed by means of a qualitative content analysis on textual data. This allows getting specific insights into organizational culture before and after DBT and about the role played by managers.

Achieved results disclose that managers need to modify the organizational culture of their firms to handle a successful DBT. However, firms can assume different organizational culture and thus the role assumed by managers handling a DBT can change as well.

To the authors knowledge, this paper is among the first that aim to investigate the role that mangers assume when handling DBTs. In particular, originality lies in the fact that assumed roles are rebuilt in reference to their ability to modify organizational culture.

This study focuses on establishing relations with some important but underestimated elements of knowledge dynamics and firm orientations to characterize organizational circular economy activities through eco-innovation (EIN). The advent of the circular economy (CE) in this post-pandemic era has brought unpredictable sustainable challenges for the manufacturing industries. This research paper aims to bring more clarity to the extant literature on the relationship between environmental innovation (EI) and CE.

In this study, a systematic literature review methodology was used to research the determinants of EI in the knowledge environment that drives the implementation of a CE.

This paper proposes a framework that articulates organizational learning and orientation dynamics and offers a new set of internal knowledge resources for a corporate CE. It is found that change toward CE requires connection with EI. However, successful CE growth largely depends on leveraging knowledge resources and orientation dynamics (stakeholder orientation, sustainability orientation, organization learning orientation and entrepreneurial orientation). CE techniques are still in their early phases of adoption and their implementation is still in its development. Circular knowledge economy (CKE) has the potential to be a useful alternative to achieving thriving CE to achieve sustainability in local and global businesses operations.

This study helps companies to understand the organizational learning and different orientation dynamics for achieving CE principles. The research findings imply that EI is critical in establishing a sustainable transition toward CE through organizational learning and orientation dynamics and has garnered significant attention from academics, public policymakers and practitioners. The proposed framework can guide managers to develop sustainable policies related to the CE. This research recognizes that firm-level CKE is important in shaping how knowledge resources relate to CE within transition management literature.

This paper abridges the knowledge gap in identifying key drivers and presents the current eminence, challenges and prognostications of sustainable EI parameters in the changing climate of CE. This study builds a framework that combines insights from different viewpoints and disciplines and extends one’s understanding of the relationship between EI and CE. From a theoretical perspective, this study explains the knowledge management complexity links between EI and CE. It builds a theoretical bridge between EI and CE to illustrate how firms transition toward CE following the recommendations. Thus, researchers should continue to support their research with appropriate theories that have the potential to explain EI and CE relationship phenomena, with a particular emphasis on some promising but underutilized theories such as organizational learning, dynamic capabilities and stakeholder theories.

The purpose of this paper is to illustrate how cryptocurrencies are being used as a vehicle for financial crime (such as money laundering, terrorist financing and corruption) and propose a more effective international standard for regulation that uses the Liechtenstein blockchain act as a benchmark.

This paper investigates how cryptocurrencies facilitate financial crime through a qualitative study consisting of interviews with 10 presumed providers of illegal financial services and 18 international compliance experts.

This study shows that cryptocurrencies are a highly suitable vehicle for money laundering, terrorist financing and corruption and that current compliance efforts in the cryptocurrency sector are ineffective.

The presented findings illustrate that for a more effective combat of financial crime via cryptocurrency, an international standard for blockchain and cryptocurrency regulation must be created. This paper suggests that Liechtenstein’s innovative and comprehensive blockchain act could be used as a basis for said standard. Practitioners should also consider cooperating transnationally when prosecuting financial crime via cryptocurrency.

The fact that cryptocurrencies facilitate financial crime is widely known. However, this study combines the perspectives of both compliance experts and presumed criminals to gain a comprehensive understanding of the techniques that money launderers, terrorist financiers and corrupt public officials use. This paper examines the potential for the innovative Liechtenstein blockchain act, which has, thus, far not received empirical attention, to set the benchmark for international regulations.