Ehi Eric Esoimeme is the author of The Risk-Based Approach to Combating Money Laundering and Terrorist Financing.
Financial Expert has rated the title as the #5 best money laundering book of all time in its 2021 refresh of the rankings. Many congratulations to Ehi, who has demonstrated his mastery of the pen and the rule book with this title. Don’t just take our word for it, the book is currently rated 5/5 stars on Amazon.co.uk.
We reached out to Ehi after the ranking was announced, to ask if he’d be generous enough with his time to share some insights into his money laundering title, and provide some advice to other financial writers out there.
Ehi Eric Esoimeme has written titles which fall under the following genres:
His other titles include:
We know that you’re here for the interview, so without any further ado please find Ehi’s responses to our interview questions laid out below:
Ehi Eric Esoimeme Interview
1) Please could you tell us a little about your professional background and why you felt inspired to write the book?
Eric: I am the Managing Partner of E-Four and AAF (a global consultancy firm that also offers training and education to financial institutions on anti-money laundering compliance). I am also concurrently the Director of Engagement & Outreach and a Senior Trainer at the Singapore Financial Crime Compliance Association (SFCCA) for Africa & Nigeria. My area of specialism and expertise is in countering financial crime. This is categorized into regulatory law, substantive law, and professional compliance guidance in terms of strategic management of money laundering risks and vulnerabilities.
My skill and knowledge in the field of the financial crime space are drawn from my many years of experience as a researcher in anti-money laundering laws and policies, counter-fraud measures, and anti-corruption strategies. So far, I have authored more than 40 publications, including eight books on money laundering law/banking law.
I am a fellow of the Institute of Management Consultants, a senior member of the Risk Management Association of Nigeria, a certified anti-corruption consultant and a member of the International Institute of Certified Forensic Investigation Professionals Inc., USA. I currently sit on the editorial board of the International Journal of anti-corruption published by the Law Faculty, Universitas Lampung and review manuscripts for several international journals.
Part of my inspiration to put together The Risk-Based Approach to Combating Money Laundering and Terrorist Financing was drawn from one of my research papers: The Importance of Why Firms Dealing with PEPs must adopt a risk-based approach to their compliance programmes. The paper was written as a research assignment for my LLM degree programme at Cardiff University. I had a distinction in that paper. The paper broadened my interest in the risk assessment topic. It also enabled me to really understand the risk-based process, and its importance in Accountable Institutions. The paper drove me to carry out more extensive research in the area of risk assessment.
The book was also inspired by the efforts and commitment put in by Academics and Lecturers of the Faculty of Law, University of Lagos to fight financial crime through public awareness and lectures.
2) In the course of researching and writing your book – did you come across anything that surprised you?
Eric: The best part about research and writing is the surprises. My initial thought was that the issue of non-compliance or partial compliance with the Financial Action Task Force key and core Recommendations was confined to jurisdictions that had been ranked non-compliant or partially compliant by the Financial Action Task Force. But my research revealed that many financial institutions around the world have failed to implement an effective system of internal controls reasonably designed to ensure compliance with regulatory requirements and the Financial Action Task Force Recommendations. Administrative cases revealed that a number of financial institutions in Africa, Europe and North America have failed to implement an adequate risk-rating methodology that evaluated customers, based on specific customer information, with a balanced consideration of all relevant factors including country/jurisdictional risks, products and services provided, nature of the customer’s business, and volume of transactions. Available evidence suggests that many financial institutions in Africa, Europe and North America constantly failed to apply commensurate enhanced due diligence practices and transaction monitoring methodologies to manage recognized risk. These deficiencies impaired their ability to appropriately assess the risks associated with particular customers. At one point, a particular Bank only identified a customer as high-risk if the customer had an average balance of $250,000 or more in a checking or savings account, or performed cash transactions totalling over $250,000 a month.
My research also revealed that the automated transaction monitoring systems of many financial institutions were inadequate to support the volume, scope, and nature of international money transfer transactions conducted by them. The automated transaction monitoring systems were designed to monitor international correspondent transactions at the bank level, and were not designed to readily identify suspicious elements, “Red Flags” or suspicious activity associated with individual transactions. In addition, the monitoring system’s programming, methodology, and effectiveness were not independently validated to ensure that the models were detecting potentially suspicious activity.
3) For budding financial writers, what is the one piece of advice would you give to those writing to educate beginners about finance?
Eric: My advice to aspiring authors is to be very patient during the whole process of research and writing. You must commence with extensive research on a general topic. The scope and direction won’t be very clear at the preliminary stage so you have to keep reading wide. The initial research will be very elaborate and extensive; It is after this that you will have a clear path as to what to write about. Once the direction is clear you have to start writing immediately. Do not wait for the entire research to be complete before you start writing. The trick to writing is to start writing. You can then adopt the approach of always reviewing what you are writing before giving it to other professionals to review. If you write part of a chapter on day 1 you should edit that same chapter on day 2 before starting something new. Chances are that you will likely delete a few sentences or rewrite a few sentences. This is the process of becoming your own critic. You should also try to make each chapter as practical as it can be while making it easy for readers to understand.
4) What else do you have going on that you’d like our readers to know about?
Eric: My firm, E-Four and AAF offers consultation services to financial institutions and designated non-financial institutions on the latest technological innovations that provide complete customer lifecycle risk coverage – accounting for customer onboarding, ongoing due diligence and enhanced due diligence (EDD) processes. We critique anti-money laundering policies/programs and customer due diligence (CDD) solutions to identify areas that need reforms and proffer recommendations where necessary. We also offer consultation on the most relevant regional approaches to confronting financial crime, and the AML software solutions that can accurately identify and report suspicious transactions while reducing false positives.
My Firm, E-Four and AAF also offers training, awareness and capacity-building on how banks and other financial institutions can structure their compliance programs to address their risk profile, based on the institution’s assessment of risks, as well as to comply with anti-money laundering (AML) regulatory requirements. The training will also focus on anti-money laundering software solutions that can accurately identify and report suspicious transactions while reducing false positives. The training advocates for a hybrid approach to compliance where traditional rules-based systems like Robotic Process Automaton can automate the straightforward, repetitive tasks, whereas cognitive technologies can automate the judgment based and predictive steps. For more information on our training modules and course outline, kindly reach out to me at [email protected] With respect to AML Certification courses, the Singapore Financial Crime Compliance Association (SFCCA) is offering its course in Africa in collaboration with my firm E-Four and AAF. I am the Director Engagement & Outreach for Africa & Nigeria, for SFCCA. I am also on the SFCCA Trainer faculty as a Senior Trainer. SFCCA Certificate courses in Financial Crime Compliance (FCC) for Private Banking & Securities (PB&S) cover Singapore & Hong Kong risks, regulations and best practices. The practices in these centres are based on the Financial Action Task Force (FATF) Recommendations and so the skills are largely exportable across centres, whether in Asia, Middle East or Africa. The SFCCA Certificate Courses help you to acquire essential regulatory knowledge, practical compliance skills, and a business-specific focus. We currently have students from Singapore, India, Pakistan, and UAE. Bankers in Nigeria and Africa can reach out to me on Training and Certification courses with SFCCA. My SFCCA email is [email protected]
In addition to our Consultation and Training services, my firm, E-Four and AAF can provide for an independent evaluation of the adequacy of your institution’s overall anti-money laundering and combating the financing of terrorism (AML/CFT) programme. This independent testing can be conducted by our team of experts, led by me, to evaluate the quality of risk management for your institution’s operations, departments and subsidiaries. This will ensure that the institution is in compliance with the required institutional, statutory and regulatory AML/CFT requirements, avoiding financial and other institutional risks that could adversely affect the institution’s reputation and business.
5) And finally, I like to ask all authors; when saving and investing your own money, what is your preferred investing style?
Eric: I don’t use a one size fits all strategy for investment. My decision is based on my level of tolerance for risk at the time of investment. I adopt the value strategy when I need to kick start a new project in a year or two with funds from the investment, and the growth strategy when I need to kick start a new project in a few months with funds from the investment.
Many thanks again to Eric for agreeing to be interviewed on Financial-Expert.co.uk. We wish him every success in his varied career.