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We recently supported a client in the corporate investigations sector in conducting due diligence on a wealthy European businessman in the luxury industry. The subject was a high-profile individual with an extensive media footprint. 

In the first 24 hours, we conducted a feasibility study to assess: 

  • The subject’s profile: Is he well-known or has a low online footprint?
  • The local jurisdiction’s information landscape: Is it easy to find information about the subject online? Are local sources used to provide commentary for compliance due diligence investigations?
  • Our capacity: Do we have expertise in conducting research in this jurisdiction? Do we know sources from previous investigations in the country or the sector? Can we be introduced to relevant sources? 

Based on this feasibility study, we accepted the case. 

In the first phase of the research, we mapped available sources based on two approaches: 

  • Open source research: peers, former colleagues, university colleagues, and journalists familiar with the subject, among others.
  • Personal networks: pre-established sources of team members in the specific jurisdiction or sector.

The second phase involved contacting the identified sources. Eight sources were available and willing to talk about various reputational issues linked to the subject, from his management style to his ties with the local elite. Three of these eight sources were identified through the team’s personal networks, while the rest were found via open-source research. 

In the third and final phase, we prepared the report, which comprised two main sections: an executive summary tailored to the client’s needs and detailed commentary, including direct quotes from the sources.

This investigation allowed us to confirm the subject was linked to extreme-right parties in the local jurisdiction. Also, several sources described his management style as “unpredictable and unreliable.”



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FATF lauds Oman’s measures to combat money laundering and terrorism financing

In December 2024, the Financial Action Task Force (FATF) reported that Oman has significantly improved its legal, operational and supervisory framework on anti-money laundering and combating the financing of terrorism (AML/CFT) in recent years through robust technical compliance with the FATF recommendations.

The mutual evaluation of Oman assessed the effectiveness of the country’s measures to combat money laundering, terrorist financing, and proliferation financing and their level of compliance with the FATF recommendations during an on-site visit between January and February 2024.

Access the source here

FATF says Argentina has improved AML/CTF measures

In December 2024, the FATF said that Argentina had strengthened its laws and processes on AML and CFT since its previous mutual evaluation in 2010, which highlighted substantial gaps in compliance. However, Argentina still faces shortcomings in delivering effective outcomes, apart from cooperation with international partners, where it is achieving positive results.

The mutual evaluation of Argentina assessed the effectiveness of the country’s measures to combat money laundering, terrorist financing, and proliferation financing and their level of compliance with the FATF recommendations during an on-site visit in March 2024. 

Access the source here

US appeals court halts enforcement of AML law

A United States (US) appeals court halted on 26 December 2024 the enforcement of an AML law that requires corporate entities to disclose the identities of their real beneficial owners to the US Treasury Department ahead of a deadline for most companies to do so. The New Orleans-based court reinstated a nationwide injunction issued by a federal judge in Texas who had concluded the Corporate Transparency Act was unconstitutional.

Most companies had faced a 13 January 2024 deadline to submit their initial reports to the Treasury Department’s Financial Crimes Enforcement Network (FinCEN). But in light of the order, FinCEN said on 27 December 2024 that companies are not required to file beneficial ownership information with the agency. “However, reporting companies may continue to voluntarily submit beneficial ownership information reports,” FinCEN said.

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Canada proposes more powers for AML regulator amid increasing scrutiny

Canada proposed new measures that will help its AML regulator impose stronger penalties for financial crimes after a big national bank pleaded guilty in the US for failures in its compliance program. In a fiscal update released on 16 December 2024 and known as the Fall Economic Statement, the country proposed changes to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act that include a 40-fold surge in penalties, criminal offence for false or incomplete information by a reporting entity, and a 10-time jump in fines for all criminal offences.

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MONEYVAL publishes progress reports on Croatia, Georgia, and Monaco

The Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) published in December 2024 follow-up reports on Croatia, Georgia, and Monaco assessing their compliance with the 40 FATF recommendations.

Croatia has taken numerous steps to strengthen its AML/CFT systems and has improved its compliance with several FAFT recommendations. As a result, the country is rated compliant or largely compliant with 36 FATF recommendations and partially compliant with four of them, MONEYVAL said.

Georgia has improved its AML/CFT measures, especially in relation to the assessment of AML and CFT risks and regulation of virtual assets service providers. However, it is still rated as non-compliant on a recommendation related to non-profit organizations and partially compliant on eight other recommendations, according to MONEYVAL’s report on the country.

Monaco has made significant progress in complying with the FATF standards since the adoption of the mutual evaluation report in 2022. MONEYVAL found the country largely compliant with FATF recommendations.

Croatia and Georgia – in one year – and Monaco – in three years – are expected to report back to MONEYVAL on further progress the countries achieve in strengthening their measures against money laundering and the financing of terrorism.

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Turkey introduces stricter cryptocurrency regulations to combat financial crime

Turkey introduced new cryptocurrency regulations during the final week of 2024, requiring users executing transactions of more than TL 15,000 (USD 425) to share their identifying information with the country’s crypto service providers. The new regulations, set for implementation on 25 February 2025, aim to prevent the laundering of illicit funds and terrorism financing through cryptocurrency transactions.

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AML/CTF amendment act overhauls Australia’s legislative landscape

On 10 December 2024, Australia’s Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 received royal assent. Set to commence in March 2026, this legislation makes material amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and brings about significant reform to Australia’s AML/CTF regime. It aims to strengthen compliance, mitigate financial crime risks, and adhere to global compliance standards. 

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“Thomas Dournon, Manager of Square Facts’ office in Rabat (Morocco), shares with us his perspective on the analyst profession”

What is the role of a risk and compliance analyst?

The compliance industry was initially focused on conducting financial due diligence within the banking and financial sectors to safeguard investments. Over time, its scope has significantly expanded. However, due to the discreet nature of our work, misconceptions and myths about our role remain prevalent. To clarify, at Square Facts, we are neither investigators nor IT compliance specialists. Instead, we focus on assessing extra-financial risks for our clients, particularly those related to their political, economic, and operational environments.

Navigating a complex environment amid a massive amount of data

Our analysts rely on various tools and techniques to gather Open-Source Intelligence (OSINT) from publicly accessible sources, including official registries, corporate websites, social and professional media platforms, online newspapers, specialized publications, and judicial and sanctions databases. The other side of the coin is what we call Human Intelligence (HUMINT) — high-value information obtained from individuals qualified to comment on specific topics.

Our team’s core expertise in collecting and analyzing information

The cornerstone of our work is interpreting information that is already in plain sight. This process underscores the indispensable role of human skills, which cannot be fully automated. Analysts must possess a diverse skill set, combining innate qualities with competencies developed through rigorous training and practice. Curiosity and critical thinking are essential to leave no stone unturned, while proficiency in foreign and rare languages enhances the ability to connect with human sources and obtain nuanced, high-value information.

What sets us apart

One skill, however, sets exceptional analysts apart: the ability to put people at ease and engage them in meaningful discussions on strategic topics. Such conversations often yield invaluable insights into the risks and challenges our clients face, which allows them to make better-informed decisions.

“We help businesses and organizations of all sizes understand the challenges impacting their reputation and commercial success.”

Thomas Dournon, Manager of Square Facts’ Rabat office
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