Effectively Fight Financial Crime With These 4 Pillars

Oliver Wyman Partner Sean Kennedy sits down with John Cusack, chairman of Global Coalition to Fight Financial Crime, to discuss takeaways from the APAC Fighting Financial Crime Conference held on April 1, 2025, including progress on anti-fraud legislation, the relationship between human trafficking and scams, and four strategies to enhance the effectiveness of tackling scams and money laundering.

INFocus Series
INFocus provides exclusive insights and trends from experts and leaders across the Asia Pacific region, exploring the forces, opportunities, and challenges shaping its future.

Go to series

John Cusack

We have to be targeting reducing harms from financial crime, the profits from financial crime, the cost to society from financial crime. We should be increasing the cost of money launderers in laundering their illicit funds. 

[series intro clip]

Sean Kennedy 

Hi, I'm here today with John Cusack, the chairman of the Global Coalition to Fight Financial Crime. Welcome, John. 

You have been on the road quite a lot. An amazing event with the HKMA (Hong Kong Monetary Authority) here in Hong Kong. Lots of dialog, lots of good ideas. What are your key reflections? 

John

Financial crime happens all over the world. We have to travel and talk to people who are fighting and trying to combat it. I was in Mumbai last week; last week was a collaboration conference, which meant coming together – public sector, private sector, and the third sector NGOs as well to talk about all the issues that were important. It felt really different from the ones that I've been to before. 

In particular, while standards need to stay high, and effectiveness is an open question, one of the big discussions we had was around whether or not some of the standards have been implemented in a way that causes perhaps unintended consequences, like significant financial exclusion. 

Sean

You mentioned collaboration. The big takeaway I had from yesterday's discussion was that sort of momentum and positive energy around it. We were kind of reconnecting and said, we first met about ten years ago. We were talking about the SAR (Suspicious Activity Reporting) reform program that we were trying to reimagine how all that system would work. 

In the last five years, the doubling down on thinking about the national infrastructure and the collaboration models, all of these changes that are happening globally with countries around the world, and even now the thinking around cross-border collaboration was super encouraging. I do think the one impressive thing that came out of it was the comments from the HKMA and their commitment to start to do more and more of that here in Hong Kong. 

John

We thought we'd get to where we are today a bit faster. Frankly, it is [been] ten years, but we've made a lot of progress in the last twelve months. It has made huge progress in lots of different places, including places like Mexico, the US, the EU and the UK, Singapore, UAE, and also in Hong Kong. Hong Kong last week announced new laws and regulations that are coming fairly soon, hopefully once they are passed by the legislature, which will enable private to private information sharing, something we have always been promoting as the key to unlock greater effectiveness. 

Sean

One of the things that was a topic that was discussed at length, and I know it was also a topic at FATF (Financial Action Task Force), was the notion that sort of regulators were thinking about reviewing the risk-based approach, and the risk-based approach has been around 20, 25 years, right? What do you think is behind that, and what kind of direction do you think that will take? 

John 

[Reviewing the risk-based approach] is a significant initiative. For the industry in particular, we have been arguing that we see examiners too much focused on technical compliance, auditing a bank's compliance program, as opposed to focusing on whether or not an institution is really, truly understanding the nature of the threats that it faces and that the controls are proportionate to those threats. That is a different kind of approach.

Of course, following regulation is a requirement, but if you only follow regulation and you don’t respond to the threats, potentially there is a significant vulnerability. Now I think everyone understands that, but it's much more difficult for regulators to necessarily examine that. I mean, what do you think? 

Sean 

I thought one of the things that was most interesting was the amount of guidance that goes out about high risk, [but] there was no real dialog about what you do with lower risk and how you would treat that. Moving from technical compliance to more about outcomes will be positive. Recognition that a lot of the stakeholders have finite resources, and they have to think about how to stack those in a proportionate way towards the risks and the threat landscape that they have to deal with, would be a very interesting and positive change in the industry. 

John

Look, if we want to take information-sharing partnerships to the next level, that means institutions are going to invest in that. They cannot just keep investing; they have got to have some relief in relation to lower risk issues, as you say. Now what does lower risk relief look like? It is very hard to say. People won’t say what it is, but it means doing less of something that is being done today. 

For me, I do have a proposal, which is taking away adverse media screening for low-risk customers in places like retail as an automated process. You do that on an ad hoc basis when it is necessary. When we first started doing adverse media [screening] it was at the top end for PEPs and for private banking or wealthy clients, where there was much more information in the public domain about those people. There is very little information in the public domain about people like you and me – regular people. Usually it is a false positive, almost always a false positive, but it causes a huge amount of noise and a huge amount of effort. I am not sure that effort necessarily translates into effectiveness. 

That's my proposal. Some people agree. Some people don't. Let's give something a try to relieve some of the excess and put those resources to where they make the most difference, which is at the top end on the high-risk areas. 

Sean

Oh, I agree. It actually makes me think about how you could make room for some of the other things that maybe don't get as much attention, that but need to. 

Another thing that struck me yesterday was the inclusion of the voices of the NGOs. Particularly the discussions that we had around human trafficking and illegal or illicit wildlife trade. I mean, it was a shocking statistic to hear that currently today, we have 50 million people that are considered in slavery, the highest in history.  And that 25% of those are children. 

But equally, when we look at illicit wildlife trade, I was quite surprised to see that Hong Kong ranked number four in legal wildlife trade. That means that there is so much [trade] that's not being caught or captured. I’m just curious, do you think we are doing enough? 

John

Human trafficking generates about half a trillion dollars a year. Wildlife trafficking generates about $250 billion. These are real serious numbers almost coming up to drug trafficking and organized crime. So, it is a big industry. 

Financial crime itself is probably a top ten global industry, and it's probably the most profitable because we only confiscate less than 1%, about 0.2% of the total amount. It is something that we have to understand in detail if we're going to tackle it. Therefore, we all have to come together, all the stakeholders – public sector, private sector, and those that know some of this stuff best and the most committed, which are the NGOs. That is why yesterday was so important to have. 

What did we have? We had the police, we had customs, we had regulators, we had banks, we had crypto. We're all in the same room discussing these topics. That is what the Global Coalition to Fight Financial Crime is all about, bringing those stakeholders together. 

Sean

The other thing I took away from it was the changing nature of human trafficking and the sheer volume that is feeding the fraud and scam spikes that we're seeing. The sad thing is the people that are being exploited and brought into these centers are being forced to perform these activities. 

John

This scam issue is a real and present danger and it's increasing. Albeit there is a response that has been demonstrable and substantive, it is not enough. 

As you say, this explosion of scams and the volume of scams and its exposure to all of us to this means that we really have to look at this in a new way and treat this in a way [that’s] almost as though it's a national security threat, because we're all targeted for this. Certain parts of Southeast Asia, hundreds of thousands of generally young people who are kidnaped after they've fallen victim to a job scam and then put in scam centers working 14-, 16-hour days to try and scam people like you and me and everyone else and get beaten if they don't, and then the scam itself is a romance scam, followed by an investment scam. 

Significant amounts of money are being lost to this. It is a combination; it is a hybrid type of thing. It includes human trafficking, and it includes fraud and scams. Having said that, what was really nice to hear is that in Hong Kong, the increase in volume is reducing. In Australia recently the number the total number of losses came down a bit. Singapore still went up. The numbers were going up substantially in Japan. In the region but also elsewhere, it is probably the most critical type of financial fraud and scam type that we need to focus on right now. 

Sean

There was a big part of the discussion that really revolved around effectiveness. The entire industry has been on a journey, and we've mentioned standards that were 20, 25 years old and some of the progress in the last ten years. But there is an emphasis now to look at what is effectiveness, and looking at these siloed risks – whether it is fraud, scams, AML, whatever – what are your views? 

John

For me, I think I'll give you four. We have to be targeting reducing harms from financial crime, we have to be targeting reducing the profits from financial crime, and we have to be targeting reducing the cost to society from financial crime. 

And the fourth one, my key KPI, would be: how much does it cost the money launderer to launder money? We should be increasing the cost of money launderers in laundering their illicit funds. 30 years ago, when FATF was set up, FATF estimated that just before they were set up, it was about 4% – four out of 100 cents on the dollar were the cost of laundering money. After two years, they thought it was between six and eight, which means it is going in the right direction. 

Last year, in the TD Bank USA case, it was disclosed in the US that professional money laundering was 2%. Some people think it's closer to zero, right?  Now that has got to be turned completely around again. The reason that's happening is because we live in a very complex world, and there's many more different ways of making payments and transferring value than there ever was, 20 or 30 years ago. Many more opportunities and avenues that are not well-permissioned. They're not well-governed. There's lots of opportunities to be able to circumvent the formal financial system and use the formal financial system in some ways. We've got a long way to go. 

Sean 

When I think about effectiveness, let’s bring it closer to home to at least some of my clients. There is a super strong emphasis on metrics and operational performance, maybe quality. Some of them are moving towards more of an intelligent lens and trying to find real insights. But I think in all of it, the effectiveness part that misses a lot of radar and a lot of people are the actual frontline stuff – they are working against tight deadlines, efficiency targets, regulatory requirements, but they lose the sight of the purpose and the pride. 

John

I think that came through yesterday, didn't it? That discussion around how your staff in places like banks, who are dealing with people who have had their life savings stolen from them and are in a wretched state, have to speak to those people on a regular basis but somehow not immune to also being affected by those circumstances. I never really appreciated that until yesterday. I heard it and it was clear and stark, wasn't it? 

Sean

Yeah. I wanted to ask you one last question. What's next for the Global Coalition? What's on your agenda? What's the mission, and where do we go from here? 

John

I think we need more people to join the Global Coalition. That is not membership; that is people to continue to be committed to the fight against financial crime. What we try and do is connect them up together, make them part of a bigger network that's also trying to defeat what is an organized criminal network that we are all very focused on defeating. 

Sean

I feel like today we covered a lot of ground. It was a very robust discussion where a lot of the themes are encouraging. There is a lot of collaboration that's going on globally. We can see jurisdictions that want to come together to collaborate and share information, to disrupt the networks that are sort of perpetrating all of these crimes around the world. But there's still much more to do. 

Thank you for your leadership, the passion and conviction that you've got to continue to fight this fight is impressive. 

John

Thank you, Sean. 

Oliver Wyman Partner Sean Kennedy sits down with John Cusack, chairman of Global Coalition to Fight Financial Crime, to discuss takeaways from the APAC Fighting Financial Crime Conference held on April 1, 2025, including progress on anti-fraud legislation, the relationship between human trafficking and scams, and four strategies to enhance the effectiveness of tackling scams and money laundering.

INFocus Series
INFocus provides exclusive insights and trends from experts and leaders across the Asia Pacific region, exploring the forces, opportunities, and challenges shaping its future.

Go to series

John Cusack

We have to be targeting reducing harms from financial crime, the profits from financial crime, the cost to society from financial crime. We should be increasing the cost of money launderers in laundering their illicit funds. 

[series intro clip]

Sean Kennedy 

Hi, I'm here today with John Cusack, the chairman of the Global Coalition to Fight Financial Crime. Welcome, John. 

You have been on the road quite a lot. An amazing event with the HKMA (Hong Kong Monetary Authority) here in Hong Kong. Lots of dialog, lots of good ideas. What are your key reflections? 

John

Financial crime happens all over the world. We have to travel and talk to people who are fighting and trying to combat it. I was in Mumbai last week; last week was a collaboration conference, which meant coming together – public sector, private sector, and the third sector NGOs as well to talk about all the issues that were important. It felt really different from the ones that I've been to before. 

In particular, while standards need to stay high, and effectiveness is an open question, one of the big discussions we had was around whether or not some of the standards have been implemented in a way that causes perhaps unintended consequences, like significant financial exclusion. 

Sean

You mentioned collaboration. The big takeaway I had from yesterday's discussion was that sort of momentum and positive energy around it. We were kind of reconnecting and said, we first met about ten years ago. We were talking about the SAR (Suspicious Activity Reporting) reform program that we were trying to reimagine how all that system would work. 

In the last five years, the doubling down on thinking about the national infrastructure and the collaboration models, all of these changes that are happening globally with countries around the world, and even now the thinking around cross-border collaboration was super encouraging. I do think the one impressive thing that came out of it was the comments from the HKMA and their commitment to start to do more and more of that here in Hong Kong. 

John

We thought we'd get to where we are today a bit faster. Frankly, it is [been] ten years, but we've made a lot of progress in the last twelve months. It has made huge progress in lots of different places, including places like Mexico, the US, the EU and the UK, Singapore, UAE, and also in Hong Kong. Hong Kong last week announced new laws and regulations that are coming fairly soon, hopefully once they are passed by the legislature, which will enable private to private information sharing, something we have always been promoting as the key to unlock greater effectiveness. 

Sean

One of the things that was a topic that was discussed at length, and I know it was also a topic at FATF (Financial Action Task Force), was the notion that sort of regulators were thinking about reviewing the risk-based approach, and the risk-based approach has been around 20, 25 years, right? What do you think is behind that, and what kind of direction do you think that will take? 

John 

[Reviewing the risk-based approach] is a significant initiative. For the industry in particular, we have been arguing that we see examiners too much focused on technical compliance, auditing a bank's compliance program, as opposed to focusing on whether or not an institution is really, truly understanding the nature of the threats that it faces and that the controls are proportionate to those threats. That is a different kind of approach.

Of course, following regulation is a requirement, but if you only follow regulation and you don’t respond to the threats, potentially there is a significant vulnerability. Now I think everyone understands that, but it's much more difficult for regulators to necessarily examine that. I mean, what do you think? 

Sean 

I thought one of the things that was most interesting was the amount of guidance that goes out about high risk, [but] there was no real dialog about what you do with lower risk and how you would treat that. Moving from technical compliance to more about outcomes will be positive. Recognition that a lot of the stakeholders have finite resources, and they have to think about how to stack those in a proportionate way towards the risks and the threat landscape that they have to deal with, would be a very interesting and positive change in the industry. 

John

Look, if we want to take information-sharing partnerships to the next level, that means institutions are going to invest in that. They cannot just keep investing; they have got to have some relief in relation to lower risk issues, as you say. Now what does lower risk relief look like? It is very hard to say. People won’t say what it is, but it means doing less of something that is being done today. 

For me, I do have a proposal, which is taking away adverse media screening for low-risk customers in places like retail as an automated process. You do that on an ad hoc basis when it is necessary. When we first started doing adverse media [screening] it was at the top end for PEPs and for private banking or wealthy clients, where there was much more information in the public domain about those people. There is very little information in the public domain about people like you and me – regular people. Usually it is a false positive, almost always a false positive, but it causes a huge amount of noise and a huge amount of effort. I am not sure that effort necessarily translates into effectiveness. 

That's my proposal. Some people agree. Some people don't. Let's give something a try to relieve some of the excess and put those resources to where they make the most difference, which is at the top end on the high-risk areas. 

Sean

Oh, I agree. It actually makes me think about how you could make room for some of the other things that maybe don't get as much attention, that but need to. 

Another thing that struck me yesterday was the inclusion of the voices of the NGOs. Particularly the discussions that we had around human trafficking and illegal or illicit wildlife trade. I mean, it was a shocking statistic to hear that currently today, we have 50 million people that are considered in slavery, the highest in history.  And that 25% of those are children. 

But equally, when we look at illicit wildlife trade, I was quite surprised to see that Hong Kong ranked number four in legal wildlife trade. That means that there is so much [trade] that's not being caught or captured. I’m just curious, do you think we are doing enough? 

John

Human trafficking generates about half a trillion dollars a year. Wildlife trafficking generates about $250 billion. These are real serious numbers almost coming up to drug trafficking and organized crime. So, it is a big industry. 

Financial crime itself is probably a top ten global industry, and it's probably the most profitable because we only confiscate less than 1%, about 0.2% of the total amount. It is something that we have to understand in detail if we're going to tackle it. Therefore, we all have to come together, all the stakeholders – public sector, private sector, and those that know some of this stuff best and the most committed, which are the NGOs. That is why yesterday was so important to have. 

What did we have? We had the police, we had customs, we had regulators, we had banks, we had crypto. We're all in the same room discussing these topics. That is what the Global Coalition to Fight Financial Crime is all about, bringing those stakeholders together. 

Sean

The other thing I took away from it was the changing nature of human trafficking and the sheer volume that is feeding the fraud and scam spikes that we're seeing. The sad thing is the people that are being exploited and brought into these centers are being forced to perform these activities. 

John

This scam issue is a real and present danger and it's increasing. Albeit there is a response that has been demonstrable and substantive, it is not enough. 

As you say, this explosion of scams and the volume of scams and its exposure to all of us to this means that we really have to look at this in a new way and treat this in a way [that’s] almost as though it's a national security threat, because we're all targeted for this. Certain parts of Southeast Asia, hundreds of thousands of generally young people who are kidnaped after they've fallen victim to a job scam and then put in scam centers working 14-, 16-hour days to try and scam people like you and me and everyone else and get beaten if they don't, and then the scam itself is a romance scam, followed by an investment scam. 

Significant amounts of money are being lost to this. It is a combination; it is a hybrid type of thing. It includes human trafficking, and it includes fraud and scams. Having said that, what was really nice to hear is that in Hong Kong, the increase in volume is reducing. In Australia recently the number the total number of losses came down a bit. Singapore still went up. The numbers were going up substantially in Japan. In the region but also elsewhere, it is probably the most critical type of financial fraud and scam type that we need to focus on right now. 

Sean

There was a big part of the discussion that really revolved around effectiveness. The entire industry has been on a journey, and we've mentioned standards that were 20, 25 years old and some of the progress in the last ten years. But there is an emphasis now to look at what is effectiveness, and looking at these siloed risks – whether it is fraud, scams, AML, whatever – what are your views? 

John

For me, I think I'll give you four. We have to be targeting reducing harms from financial crime, we have to be targeting reducing the profits from financial crime, and we have to be targeting reducing the cost to society from financial crime. 

And the fourth one, my key KPI, would be: how much does it cost the money launderer to launder money? We should be increasing the cost of money launderers in laundering their illicit funds. 30 years ago, when FATF was set up, FATF estimated that just before they were set up, it was about 4% – four out of 100 cents on the dollar were the cost of laundering money. After two years, they thought it was between six and eight, which means it is going in the right direction. 

Last year, in the TD Bank USA case, it was disclosed in the US that professional money laundering was 2%. Some people think it's closer to zero, right?  Now that has got to be turned completely around again. The reason that's happening is because we live in a very complex world, and there's many more different ways of making payments and transferring value than there ever was, 20 or 30 years ago. Many more opportunities and avenues that are not well-permissioned. They're not well-governed. There's lots of opportunities to be able to circumvent the formal financial system and use the formal financial system in some ways. We've got a long way to go. 

Sean 

When I think about effectiveness, let’s bring it closer to home to at least some of my clients. There is a super strong emphasis on metrics and operational performance, maybe quality. Some of them are moving towards more of an intelligent lens and trying to find real insights. But I think in all of it, the effectiveness part that misses a lot of radar and a lot of people are the actual frontline stuff – they are working against tight deadlines, efficiency targets, regulatory requirements, but they lose the sight of the purpose and the pride. 

John

I think that came through yesterday, didn't it? That discussion around how your staff in places like banks, who are dealing with people who have had their life savings stolen from them and are in a wretched state, have to speak to those people on a regular basis but somehow not immune to also being affected by those circumstances. I never really appreciated that until yesterday. I heard it and it was clear and stark, wasn't it? 

Sean

Yeah. I wanted to ask you one last question. What's next for the Global Coalition? What's on your agenda? What's the mission, and where do we go from here? 

John

I think we need more people to join the Global Coalition. That is not membership; that is people to continue to be committed to the fight against financial crime. What we try and do is connect them up together, make them part of a bigger network that's also trying to defeat what is an organized criminal network that we are all very focused on defeating. 

Sean

I feel like today we covered a lot of ground. It was a very robust discussion where a lot of the themes are encouraging. There is a lot of collaboration that's going on globally. We can see jurisdictions that want to come together to collaborate and share information, to disrupt the networks that are sort of perpetrating all of these crimes around the world. But there's still much more to do. 

Thank you for your leadership, the passion and conviction that you've got to continue to fight this fight is impressive. 

John

Thank you, Sean.