• Tuesday, December 05, 2023
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Adjoa Adjei-Twum, the financial crime compliance expert making bold, global moves

Adjoa Adjei-Twum, the financial crime compliance expert making bold, global moves

Adjoa Adjei-Twum is President/CEO Emerging Business Intelligence and Innovation Group (EBII).

Raised by her grandmother after her parents left Ghana for the UK when she was four, she rejoined her parents in the UK 10 years later but it was bittersweet. She could start a new life away from the hardship observed in many parts of Africa, but could not shake off the inequality of those left behind.

As a result, she wanted to study Economics and finance so she could make a difference to others, particularly the financially excluded. She began her banking career fifteen years ago in the UK, leading compliance teams in financial organisations including KPMG, CITI, Barclays, and HSBC.

Of the many highlights during this period, she is particularly proud of leading Barclays global compliance unit’s investigation during the Panama Papers scandal. Adjoa worked closely with regulators and bank executives to review the bank’s exposure and boost controls to combat money-laundering and illicit transactions. Her report helped the bank restructure its financial crime unit.

Similarly, while at HSBC, she was chosen to lead the financial crime assurance team after the bank was hit by a record $1.9 billion fine in 2013 relating to money laundering and sanctions breaches in Africa & Asia. Her role was to help revamp the bank’s controls, reform their internal practices and report back to the US Federal Reserve.

As an African diasporan, these experiences drove her to specialise in tackling governance and compliance challenges, because she observed the negative perception they gave African countries.

Adjoa partnered with the Oxford University Innovation incubator to launch the Emerging Business Intelligence and Innovation Group (EBII), an Africa-focused specialist compliance and risk management consultancy firm.

Her most recent project is the annual Africa Investment Risk and Compliance Summit (AIRCS) which she has hosted since 2020.

When and why was the EBII Group formed? What is the success story and what are you looking forward to achieving in the near future?

I initiated the formation of the EBII Group as a response to a culmination of experiences throughout my seventeen-year banking career in the UK, where I held leadership positions in compliance teams at esteemed financial institutions such as KPMG, CITI, Barclays, and HSBC.

Over the years, I observed a common thread concerning the perception of risk associated with African entities or business activities related to the continent. It became evident that there was a significant gap in understanding Africa within the Western world, impacting how banks conducted risk assessments on African organizations. As an African diasporan, this realisation prompted me to specialise in addressing governance and compliance challenges.

My passion for tackling these challenges stems from the recognition that negative perceptions surrounding Africa significantly impact foreign investment in African countries. There is a crucial need for the western world to gain a more profound understanding and appreciation of Africa. This gap in understanding has direct consequences on how financial institutions evaluate risk in the context of African organisations.

The EBII Group was thus established during my postgraduate studies at the University of Oxford, Said Business School, with a mission to bridge this knowledge gap. EBII Group is backed by Oxford University Innovation. We are committed to equipping African organisations with compliance best practices, enabling them to compete effectively on the international stage. Simultaneously, we aim to foster a more accurate understanding of Africa in the western world, ultimately influencing how risk assessments are conducted and encouraging increased foreign investment on the continent.

Our success story is marked by the positive impact we’ve made in challenging and reshaping perceptions. In 2022, for instance, we collaborated with the Ghana banking sector to design nationwide programs aimed at equipping the banking industry to combat financial crime. Additionally, in 2021, we partnered with the University of Oxford to launch an executive programme educating western investors about sustainable investing in Africa.

Looking ahead, our focus is on expanding our reach and maintaining our position at the forefront of transforming the narrative around Africa. We are dedicated to promoting sustainable growth and fostering mutually beneficial partnerships between African entities and the global community.

Read also: Moghalu harps on Private Sector Bill of Rights to open Africa for business

Share your experience and lessons learnt at Barclays

My tenure at Barclays was truly transformative. Initially joining as a manager in the global sanctions team during a regulatory review period, I played a vital role in investigating sanctions breaches and circumvention. My responsibilities expanded to include approving exceptions, waivers, and dispensations, as well as providing comprehensive sanctions training to the bank’s global staff.

A pivotal moment in my journey at Barclays came during the Panama Papers data leak. Elevated to a leading role within the bank, I collaborated closely with regulators and bank executives to conduct a thorough review of the bank’s exposure. This process aimed to fortify controls, particularly in the fight against money laundering and illicit transactions. The insights gathered from this effort became the cornerstone of a report that played a key role in restructuring the bank’s financial crime unit.

Following this impactful chapter, I assumed the role of Global Head of Training for the Chief Controls Office. In this capacity, I oversaw training initiatives across all 22 risk areas of the bank. One of my key achievements during this phase was implementing a global “train the trainer” program, ensuring consistent and effective training practices throughout the organization.

These experiences have been rich in lessons. I learnt the importance of adaptability in navigating dynamic regulatory landscapes and the necessity of effective collaboration, both within the organisation and with external stakeholders. The role affirmed the strategic significance of proactive compliance measures in safeguarding the integrity of financial institutions. Moreover, overseeing global training programmes emphasized the critical role of education in building a resilient and knowledgeable workforce.

In essence, my journey at Barclays has been marked by continuous growth, from managing sanctions to leading global training initiatives. It has deepened my understanding of the multifaceted nature of risk management and compliance in the financial sector.

What is the EBII Summit about? What is the latest on it?

The EBII’s annual Africa Investment Risk and Compliance Summit (AIRCS), has served as a platform that brings together political and business leaders, academics, and regulators to collaboratively address Africa’s investment challenges. Introduced in 2020, the summit has seen the participation of influential figures such as Ghana’s President Nana Akufo-Addo, Sierra Leone’s President Julius Bio, US Congresswoman Rep. Ilhan Omar, Mo Ibrahim, and African Continental Free Trade Secretary General Wamkele Mene.

Over the past three years, the summit has attracted over 5000 attendees from 80 countries, fostering partnerships with notable entities, tech giants and banks like Zenith Bank. However, the EBII Group Corp. recently announced a transformation with the launch of the inaugural African Leaders and Partners Forum in Washington, D.C. on November 16, 2023. This event serves as a reimagined replacement for the Annual African Investment Risk and Compliance Summit.

The African Leaders and Partners Forum has been established with a clear mission — to facilitate collaborative solutions to distinctive investment challenges within Africa. This exclusive community is designed to bring together a diverse group of thought leaders, including political figures, business leaders, academics, and regulatory authorities.

It is crucial to highlight that participation in this exclusive forum requires an annual membership fee, underscoring the commitment to creating a dedicated and engaged community of individuals and organisations invested in the sustainable development and prosperity of Africa.

As part of this transformative development, the EBII Group Corp., a public benefit corporation, has relocated its operations to 1300 Pennsylvania Avenue, NW, Suite 700, Washington, D.C. 20004, USA. This move is accompanied by the introduction of a new board of directors and advisory council members, signaling the corporation’s commitment to governance restructuring.

This shift reflects the EBII Group Corp.’s dedication to fostering collaboration, providing strategic insights, and serving as a trusted advisor to individuals, governments, and organisations navigating the complexities of financial markets, investment prospects, and risk management in Africa and beyond.

What are the key elements of a strong anti-money laundering (AML) programme, and what challenges do businesses face in implementing and maintaining these programmes?

Businesses often face several challenges in implementing and maintaining strong anti-money laundering controls due to:

● Complex Regulatory Landscape

● Technological Challenges

● Businesses with international operations may encounter challenges in coordinating AML efforts across different jurisdictions, each with its own regulatory framework.

● Evolving Money laundering threats such as the use of cryptocurrencies and new money laundering methodologies.

● Introducing stringent AML measures may impact the customer experience.

A strong anti-money laundering programme is crucial for businesses in detecting and preventing illicit financial activities. Financial institutions are required to take appropriate steps to identify and assess their money laundering and terrorist financing risks for customers, countries, or geographic areas, and products, services, transactions, or delivery channels.

Read also: Navigating the blockchain-fintech nexus in transforming financial services

Other key elements include:

● Identifying the customer and verifying that customer’s identity using reliable, independent source documents, data or information.

● Identifying the beneficial owner and taking reasonable measures to verify the identity of the beneficial owner, such that the financial institution is satisfied that it knows who the beneficial owner is.

● Conducting ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the institution’s knowledge of the customer, their business and risk profile, including, where necessary, the source of funds.

● Regular training to keep staff informed about evolving risks and compliance requirements.

● Developing and implementing internal controls such as policies that align with regulatory requirements.

● Finally Conducting regular independent audits to assess the effectiveness of the AML programme. External reviews help identify weaknesses and areas for improvement.

For organisations to successfully address these challenges they require a proactive approach, a continuous monitoring of regulatory changes, an investment in technological solutions, and a commitment to maintaining a culture of compliance within their organisation.

How does technology play a role in financial crime prevention, and what are some emerging technologies or tools being used in this field?

Technology plays a very crucial role in financial crime prevention by providing advanced tools and solutions to detect, investigate, and mitigate various forms of illicit activities. Some of the ways in which technology contributes to financial crime prevention include:

1. Data Analytics and Machine Learning is often used for transaction monitoring to identify unusual patterns that may indicate financial crime.

2. Advanced technologies, and artificial intelligence, are often used to effectively identity, and verify customers during onboarding and transaction processes.

3. Blockchain are often used for record-keeping, enhancing transparency in financial transactions

4. RegTech (Regulatory Technology) solutions can help organizations stay up-to-date with regulatory changes and ensure adherence to evolving requirements.

5. Robust cybersecurity measures can be very useful in protecting sensitive financial data, whilst preventing unauthorised access and safeguarding against cyber threats.

As financial crimes continue to evolve, the integration of innovative technologies continues to be crucial for maintaining effective prevention measures.

What are some red flags or indicators that may suggest potential financial crimes, and how can businesses effectively detect and investigate them?

Detecting potential financial crimes involves recognising red flags or indicators that may indicate suspicious activities. Some common red flags include:

1. Unexplained Wealth

2. Frequent Large Transactions

3. Transactions involving countries known for high levels of corruption, money laundering, or terrorist financing.

4. Unusually frequent or high-value cash transactions.

5. Swift movement of funds through multiple accounts or jurisdictions.

6. Abnormal changes in transaction patterns.

7. Irregularities in user login patterns, such as access from unusual locations or at odd hours.

Effective Investigation Measures include:
● Utilising advanced analytics and machine learning to identify unusual patterns and flag potential risks.

● Conducting thorough due diligence on high-risk customers and transactions.

● Educating employees about red flags, compliance procedures, and the importance of reporting suspicious activities.

● Establishing channels for sharing information with law enforcement agencies and regulatory bodies.

● Implementing mechanisms for employees and stakeholders to report suspicious activities anonymously.

● Leveraging technology for automated compliance checks, reducing the risk of manual errors.

● Conducting periodic audits to evaluate the effectiveness of anti-financial crime measures and identify areas for improvement.

By staying vigilant and implementing a multi-faceted approach that combines technology, employee training, and robust monitoring systems, businesses can enhance their ability to detect and investigate potential financial crimes effectively.

How has the COVID-19 pandemic impacted financial crime trends, and what measures have and can be taken to adapt to the changing landscape?

The COVID-19 pandemic has significantly reshaped financial crime dynamics, presenting both challenges and opportunities for illicit activities. Notable impacts include a surge in cyber threats, the proliferation of fraudulent schemes, and an increased risk of money laundering associated with the rise in online banking activities.

To adapt to this changing landscape, businesses can implement the following measures:

● Leverage advanced technologies, such as artificial intelligence and data analytics, to bolster financial crime detection and prevention capabilities

● Implement remote compliance assessments and due diligence procedures

● Invest in robust cybersecurity measures

● Regular training sessions to enhance employee awareness of evolving financial crime risks

Can you discuss the role of data analytics and artificial intelligence in financial crime compliance, and how these technologies help in identifying patterns and detecting suspicious activities?

Data analytics and artificial intelligence has over the years played a critical role in transforming financial crime compliance through advanced tools that identify abnormal patterns and detect suspicious activity. AI and data analytics enable real-time processing, making it easier to identify suspicious activities. In addition, machine learning models continually learn and adapt, improving accuracy in identifying patterns and anomalies.

In summary, the integration of data analytics and artificial intelligence in financial crime compliance empowers institutions to stay ahead of evolving threats, identify patterns indicative of illicit activities, and enhance overall security and regulatory adherence in the financial ecosystem.

Read also: Why addressing cyber-crime requires multifaceted approach, by Musa

What are the consequences for businesses that fail to comply with financial crime regulations, and how can they mitigate the associated risks?

By proactively addressing financial crime risks and maintaining a robust compliance framework, businesses can mitigate the associated risks and demonstrate a commitment to ethical and lawful operations.

Failure to comply with financial crime regulations can have serious consequences for businesses, including; legal, financial, and reputational repercussions. Some of the potential consequences include;

● Penalties and Fines

● Legal Actions

● Loss of Licenses / Permits

● Loss of Trust and Credibility

● Operational Disruptions

● Increased Scrutiny From Regulators

● Enhanced Regulatory Oversight

Organisations can mitigate the associated risks by doing the following:

● Having Up To Date Relevant Policies And Procedures

● Conducting Comprehensive Risk Assessments

● Implementing Robust Compliance Programme

● Conducting Appropriate Due Diligence

● Implementing Technology and Automation

● Conducting Regular Audits and Monitoring

● Employee Training

While at HSBC, you were chosen to lead the financial crime assurance team after the bank was hit by a record $1.9 billion fine in 2013 relating to money laundering and sanctions breaches in Africa and Asia. Share in details what happened and your involvement to proffer solutions.

During my tenure as the Vice President for Europe Financial Crime Compliance Assurance at HSBC, I assumed a pivotal role leading the financial crime assurance team. This responsibility came in the aftermath of a significant $1.9 billion fine imposed on the bank, due to money laundering and sanctions failings in controls related to Africa and Asia. At that critical juncture, the bank was under the oversight of a monitor appointed by the US Federal Reserve Bank, charged with ensuring the comprehensive revamping of controls within a specified time frame.

In this capacity, my primary role was to oversee Europe Financial Crime Compliance Assurance. The strategic initiative undertaken aimed not only to address past issues but also to fortify the bank’s overall resilience against financial crime risks. This concerted effort reflected a commitment to upholding regulatory compliance and ethical standards, positioning the institution on a path towards enhanced governance and risk management.

Western world sometimes lacks a proper understanding and appreciation of Africa, which impacts how banks conduct risk assessments on African organisations. What is your take on this and how are you helping to change the narrative?

The perception gap and lack of understanding of Africa in the western world indeed pose significant challenges, particularly in the context of how banks conduct risk assessments on African organisations. Addressing this issue is crucial for fostering fair and accurate evaluations, which, in turn, can positively impact foreign investment and economic opportunities for African entities.

My perspective on this matter is rooted in the belief that a nuanced understanding of the African landscape is essential for effective risk assessment. Africa is a diverse continent with unique economic, cultural, and regulatory contexts across its regions. The conventional risk models often fail to capture this diversity, leading to misinformed assessments.

We are solving this problem through the African Leaders and Partners Forum. The African Leaders and Partners Forum is making a significant impact in reshaping the narrative surrounding Africa and fostering collaboration. The inaugural forum on November 16th has garnered substantial interest, attracting a distinguished audience, including African and Asian Ambassadors to the US, US Congressmen and Congresswomen, and notable speakers such as the African Union Ambassador to the USA, Ghanaian Ambassador to the USA, Deputy Ambassador of Nigeria to the USA, Sierra Leone Ambassador to the USA, Mozambique Ambassador to the USA, Tanzania Ambassador to the USA, and a US Congresswoman from Minnesota, among others.

This initiative is poised to establish a robust Solution Network, offering a compelling value proposition through an annual membership fee. Members stand to benefit from:

1. Six (6) In-Person Solutions Summits Annually

2. Curated Topics from Exclusive Contacts:

● Access a thoughtfully curated selection of annual topics derived from EBII’s exclusive top contacts. These topics address critical issues affecting investors in Africa, ranging from market and consumer behavior to currency control, regulatory and legal environments, infrastructure, security and safety, environmental and sustainability concerns, and more.

3. Pre-Planned Consultations:

● Participate in pre-planned consultations designed to ensure that each event fosters discussions and outcomes focused on actionable solutions.

4. Post-Event Follow-Up:

● Benefit from a post-event follow-up mechanism, facilitating coordination and implementation of the solutions discussed during the summits.

Through these initiatives, the African Leaders and Partners Forum is actively contributing to creating a collaborative space that goes beyond discussions, aiming to drive tangible solutions and positive outcomes for investors in Africa.

In March 2023, you were invited by the White House as the only British National to join the delegation traveling with the USA Vice President Kamala Harris on her first official visit to Africa. What was this experience like?

In March of this year, I had the distinct honor of being invited to join the USA delegation accompanying Vice President Kamala Harris on her inaugural official visit to Africa. The journey commenced in Ghana as part of her three-nation tour to strengthen ties with the continent, marking a pivotal moment in her role as Vice President.

As a guest at the prestigious state banquet hosted by Vice President Harris and Ghana’s President Nana Addo Dankwa Akufo-Addo, I had the privilege of participating in discussions that underscored the significance of the visit.

Vice President Harris’s mission resonates strongly with themes that are close to my heart—strengthening partnerships, fostering investments to support economic growth, and advancing opportunities in Africa. Her specific focus on women’s economic empowerment, climate resilience, and the digital economy aligns with the core values of EBII Group, Corp..

It is particularly great to witness the emphasis on harnessing the potential of female entrepreneurs in Africa—a demographic often recognised as the continent’s untapped growth engine. With sub-Saharan Africa boasting the world’s highest rate of women involved in entrepreneurial activity, accounting for 58% of the self-employed population and contributing 13% to Africa’s GDP, the significance of supporting and empowering women in business cannot be overstated.

As the EBII Group, we welcome the USA’s renewed focus on Africa, acknowledging the continent’s challenges while recognising the vast opportunities it holds. From addressing debt relief and fostering inclusive economic growth to strengthening democracy and governance, the potential for positive transformation is immense.

We share Vice President Harris’s vision that, with the right support, African ideas and innovations will play a pivotal role in shaping the future of the world. This experience stands as a testament to the collaborative efforts needed to drive positive change and meaningful partnerships between nations.

Tell us about losing your husband to cancer and how you have weathered the situation, especially as a single mother. What advice do you have for anyone going through the loss of a loved one?

Amidst my pursuit of institutional impact, life delivered a profound and personal blow. In 2014, whilst in my 20s, I confronted the devastating loss of my husband to cancer, thrusting me into the role of a single mother to our one-year-old son. In the darkest moments following his burial, I underwent a spiritual awakening, meeting the Lord and encountering His divine covering was divine, I experienced a miraculous recovery over time and a new chapter unfolded. I found solace in the conviction that my journey held a greater purpose — to be a source of hope and inspiration for my generation. Balancing the advancement of my career with the responsibilities of single motherhood was not the easiest thing especially in the UK. I often took my son to most of my business meetings and met and engaged with several high profile leaders in the process, this became a great inspiration for him to dream even bigger than his mum.

Over time, I discovered my stride and developed a profound passion for drawing strength from these experiences. This passion evolved into a steadfast commitment to mentor and support others. My commitment to mentoring stems from the belief that shared experiences can serve as a beacon of hope to many.

In extending support, I provided career development guidance to a young BBC employee, assisting her in securing a position on a team advising senior leadership. This led to BBC HR inviting me to mentor 20 inspiring black leaders. Additionally, I have mentioned several business leaders in different sectors and jurisdictions and most recently supporting When Females Lead mentorship of women in the boardroom. In 2021, I received recognition from Espire Oxford on their ‘Wonder Women’ programme, celebrating inspiring female leaders. The BBC also acknowledged my contributions on International Women’s Day, honoring me as a leading woman in finance. These accolades affirm the impact of mentorship, highlighting the importance of uplifting others on their journeys of growth and achievement.