The Hidden Environmental Cost of Financial Laundering as a Service (FLaaS)

by Michelle Armstrong, TYS Global VP of Value Solutions Consultant

In the digital age, the “as a Service” model has revolutionized how we access technology, from software to infrastructure, making it easier and more efficient for businesses and consumers alike. However, this model’s darker iteration, Financial Laundering as a Service (FLaaS), poses significant challenges not just to the global financial system but also to environmental sustainability efforts, particularly in managing Greenhouse Gas (GHG) emissions. While the connection between financial laundering and environmental degradation might not be immediately obvious, the ripple effects of FLaaS can undermine global efforts to combat climate change in several ways. 

Diverting Crucial Resources
The fight against FLaaS requires substantial financial, technological, and human resources. Governments and businesses must invest heavily in detecting, preventing, and prosecuting financial laundering activities. These resources could otherwise be allocated to renewable energy projects, conservation efforts, and the development of low-carbon technologies. The diversion of such resources compromises the effectiveness of GHG management initiatives, delaying progress in the transition to a sustainable and low-carbon economy. 

Undermining Regulatory Frameworks
Financial laundering is often linked with environmental crimes, such as illegal logging, wildlife trafficking, and unregulated mining. These activities directly contribute to GHG emissions and are driven by the profitability enabled by laundering illicit proceeds. FLaaS, by facilitating easier and more accessible financial laundering, can exacerbate these environmental crimes. It undermines regulatory efforts aimed at promoting sustainability and holding businesses accountable for their environmental impact, making it more challenging to enforce laws designed to reduce GHG emissions. 

Impact on Corporate Governance and Investment
The involvement of any business in FLaaS, directly or indirectly, can lead to significant reputational damage. This undermines corporate social responsibility (CSR) efforts, including commitments to environmental sustainability and GHG emission reductions. Furthermore, the opaque nature of financial flows resulting from FLaaS can lead to investments in industries with high GHG emissions, rather than in clean energy and green technologies. Strengthening anti-money laundering (AML) measures can redirect investments toward sustainable initiatives, promoting environmental stewardship and reducing GHG emissions. 

Economic Stability and Environmental Policy
A stable and transparent financial system is foundational to effective environmental governance and the implementation of GHG management policies. Financial laundering, particularly through FLaaS, threatens this stability, potentially corrupting the political processes essential for environmental policy-making. The destabilizing effect of laundered money can impede the allocation of public funds to critical environmental projects and weaken international cooperation on climate change mitigation. 

The Path Forward
Combating FLaaS is not just a financial imperative but an environmental necessity. Strengthening AML measures, enhancing international cooperation, and fostering transparency in financial transactions can mitigate the adverse effects of FLaaS. By ensuring that financial systems are not exploited for laundering activities, we can secure the resources and stability needed to address GHG emissions effectively. Investments can be channelled into sustainable industries, driving innovation in green technologies, and supporting the global transition to a low-carbon economy. 

Trust Your Supplier (TYS) stands as a critical tool in the arsenal against the environmental degradation exacerbated by FLaaS. By leveraging blockchain technology, TYS provides a secure and transparent platform for managing supplier information, ensuring that data integrity is maintained across the supply chain. This level of transparency is vital in identifying and mitigating the risks associated with suppliers that may be involved in environmental crimes or lack proper compliance with environmental regulations. Through comprehensive MDM capabilities, TYS allows companies to maintain an accurate and up-to-date repository of supplier data, including their environmental compliance records. This data can be instrumental in making informed decisions about which suppliers to engage with, prioritizing those that adhere to sustainable practices and contribute positively to GHG management efforts. 

TYS’s robust risk and compliance monitoring features enable businesses to proactively assess and manage the environmental risks associated with their suppliers. By setting criteria for compliance with environmental standards, TYS can help flag suppliers that fall short of these benchmarks, allowing businesses to take corrective action before any reputational or regulatory consequences arise. This is particularly relevant in industries prone to high GHG emissions, where selecting environmentally responsible suppliers can significantly contribute to a company’s overall sustainability goals. 

In the battle against FLaaS and its indirect facilitation of environmental harm, Trust Your Supplier emerges as a potent solution to ensure that businesses do not inadvertently support activities contributing to GHG emissions. By fostering a more transparent, compliant, and sustainable supply chain, TYS not only aids in the fight against financial crimes but also aligns with global efforts to mitigate climate change. This dual function underscores the importance of integrating advanced supplier management tools like TYS in strategic efforts to secure a sustainable future, making it clear that the fight against financial laundering is inextricably linked with the broader struggle for environmental sustainability. 

Shielding the Financial Frontline

Master Data Governance and Continuous Monitoring in the Battle Against FLaaS

by Michelle Armstrong, TYS Global VP of Value Solutions Consultant

The digital age has ushered in unparalleled opportunities for the banking and insurance sectors, driving innovation and customer convenience to new heights. However, this transformation has also opened the door to sophisticated financial crimes, notably Financial Laundering as a Service (FLaaS). This emerging threat utilizes the digital world’s complexity to obscure illicit financial flows, posing significant risks to the integrity and stability of financial institutions and insurance companies. Addressing this challenge requires more than traditional measures; it demands a strategic approach centered around master data governance and continuous monitoring.

The Growing Threat of FLaaS
Understanding FLaaS: Financial Laundering as a Service represents a sinister evolution of money laundering, exploiting digital platforms to clean dirty money. By offering laundering services as a package, FLaaS operators provide criminals with anonymity and operational ease, complicating the task of tracking and combating these activities for financial bodies.

Impact on Banking and Insurance Markets: The banking and insurance sectors, integral to the global financial ecosystem, are particularly vulnerable to FLaaS. The potential for regulatory penalties, reputational damage, and financial losses from FLaaS activities is immense. The intricate nature of these markets, combined with the volume of transactions, creates numerous blind spots that FLaaS exploits.

Master Data Governance: A Shield Against FLaaS
Defining Master Data Governance: Master data governance refers to the management and oversight of an organization’s critical data to ensure accuracy, consistency, and security. In the context of combating FLaaS, it serves as a foundation for integrity and transparency across financial transactions and relationships.

Role in Combating FLaaS: By implementing robust master data governance, banks and insurance companies can significantly enhance their ability to detect and prevent money laundering activities. This approach ensures that all transactional data is accurate and traceable, making it more difficult for FLaaS operations to succeed.

Continuous Monitoring: The Watchful Eye
The Need for Continuous Monitoring: Given the dynamic nature of FLaaS, static security measures are insufficient. Continuous monitoring provides real-time oversight of transactions and activities, enabling the early detection of suspicious patterns that may indicate money laundering.

Benefits for the Financial Sector: Continuous monitoring, supported by advanced analytics and AI, allows for the automatic identification of anomalies in transaction data. This capability is crucial for maintaining compliance with evolving regulatory requirements and protecting against the reputational risks associated with FLaaS.

The battle against Financial Laundering as a Service is complex and ongoing. For the banking and insurance sectors, the stakes are high, with the integrity of the financial system and the trust of customers in the balance. Master data governance and continuous monitoring emerge as essential weapons in this fight, offering a path to safeguard operations and ensure compliance. As the landscape of financial crime continues to evolve, so too must the strategies to combat it. Embracing these advanced measures is not just a regulatory necessity; it is a strategic imperative for survival and success in the digital age.

Navigating the ESG Landscape: How Financial Services Can Thrive in a Changing World

by Nick Picone, TYS VP of Advisory Practice, and Michelle Armstrong, TYS Global VP of Value Solutions Consultant

The financial services industry has officially passed a critical inflection point. Climate change and ever-changing environmental, social, and governance (ESG) requirements have quickly reshaped the operating landscape. This accelerating shift demands a proactive approach from banks and other large financial institutions to meet regulatory expectations and harness ESG principles for economic resilience and innovation.

It is no longer an option to sit back and ignore these challenges with regulators, investors, customers and stakeholders who are increasingly scrutinizing ESG integration and climate risk management. The imperative to change becomes even more compelling when confronted with an uncertain economic climate like we face today – where a strategic posture supporting sustainability has proven to foster operational resilience against economic downturns and inflationary pressures.

This article delves into the evolving regulatory landscape, the importance of supplier compliance, and how forward-thinking institutions can leverage emerging technology to navigate this transformative period, thereby driving the results that society now requires and ensuring economic sustainability.

The Coming Regulatory Storm: From OCC to Global Framework
The recent final guidance from the Office of the Comptroller of the Currency (OCC) in the United States and similar global initiatives in the EU underscore the growing focus on two distinct areas climate change and ESG integration. With guidance emphasizing the need for large banks to manage climate-related financial risks more effectively, the message is clear: financial stability and responsible lending practices are now critical business requirements. This regulatory push, combined with the resilience ESG-focused companies have shown during economic downturns, highlights the financial imperative to integrate sustainable practices.

Key Statistics:

Moving Beyond Compliance: Embracing ESG as a Core Business Strategy
For financial institutions, integrating ESG into the business extends far beyond compliance; it presents a strategic opportunity to innovate, mitigate risks, and enhance financial performance. Organizations are being presented with a golden opportunity to become more operationally fit. An additional value driver all organizations will benefit from is the enhanced ability to weather economic shocks and inflationary pressures by reducing operating costs and fostering resilience. Aligning with global standards like the EU Taxonomy and SFDR not only demonstrates a commitment to transparency but also attracts eco-conscious customers, offering a competitive edge in an increasingly discerning customer base.

Key Statistics:

  • A significant majority of global consumers are willing to pay a premium for sustainable products and services, highlighting the economic benefit of ESG integration. (Source: McKinsey, 2023)
  • Companies with robust ESG performance consistently outperform their peers (MSCI, 2023), underscoring the financial rationale for sustainability.

Leveraging Emerging Technology for Transformation
Effective ESG assessments and climate risk management require innovative solutions. Technologies that streamline data management and enhance risk assessment enable financial institutions to navigate the complexities of the ESG landscape quickly and efficiently. By automating compliance and leveraging advanced analytics, institutions can ensure they meet evolving regulatory requirements while driving sustainable growth.

Key Benefits:

  • Streamlining data management: Eliminate data silos and consolidate insights from diverse sources, providing a holistic view of ESG performance and climate risks. (Source: McKinsey, 2023)
  • Enhancing risk management: Utilize advanced analytics and scenario planning tools to quantify climate-related risks and inform sound decision-making. (Source: McKinsey, 2020)
  • Ensuring regulatory compliance: Automate data collection, reporting, and disclosure processes to guarantee adherence to evolving regulations like the EU Taxonomy and SFDR. (Source: Deloitte, 2022)

The Business Case To Support Change
The financial services industry plays a pivotal role in building a sustainable future. Embracing ESG and climate-conscious strategies enables long-term success, mitigates risks, and unlocks future growth. It’s also critical to partner with an emerging technology provider who will support your initiative to integrate ESG into your operational environment. Partnering with a company like TYS and leveraging a best-of-breed approach through third-party data providers like Moody’s, EcoVadis, Rapid Ratings, and Dunn & Bradstreet will ensure your organization not only aligns with regulatory requirements but also contributes to a more sustainable and economically stable future.

TYS Podcast S2E2- Mitigating Financial Risk to Unlock Added Value

In today’s fast-paced business environment, companies face numerous challenges in managing financial risk effectively while unlocking added value from their procurement processes. To gain valuable insights into this critical area, we turn to procurement experts Stephen Brandt & Chad Hill from Trust Your Supplier (TYS), and Eric Evans from RapidRatings, who share their wealth of experience and knowledge in the field. 

Stephen Brandt, a value engineer at Trust Your Supplier, emphasizes the importance of understanding regulatory goals and compliance risks in procurement. With 15 years of experience in the industry, Stephen highlights the need to uncover value while mitigating financial risks effectively. 

Chad Hill, the Chief Revenue Officer at Trust Your Supplier, underscores the significance of leveraging technology to enhance supply chain management. With over 17 years of experience in procurement technology, Chad emphasizes the importance of collaboration and amplifying the mission of delivering value to the market. 

Eric Evans, a seasoned expert with 20 years of experience in data risk and compliance, provides valuable insights into the role of predictive analytics in managing financial risk. As a partner at Rapid Ratings, Eric discusses the impact of rising interest rates and leveraged debt on companies, particularly in the wake of the COVID-19 pandemic. 

One of the key challenges highlighted by Eric is the need to assess the financial health of critical relationships within the supply chain. By segmenting companies based on their criticality and leveraging predictive analytics, organizations can gain deeper insights into potential risks and opportunities. 

Furthermore, Eric emphasizes the importance of continuous monitoring and due diligence in supplier onboarding processes. With the help of platforms like Trust Your Supplier, organizations can customize their monitoring strategies to align with their specific needs and priorities. 

Chad echoes the importance of resilience in today’s business landscape, emphasizing the interconnected nature of financial, operational, and environmental risks. By leveraging technology and expert insights, organizations can better anticipate and mitigate potential risks, ensuring long-term sustainability and growth. 

In conclusion, mitigating financial risk in procurement requires a holistic approach that integrates technology, expertise, and strategic partnerships. By leveraging predictive analytics, continuous monitoring, and customized solutions, organizations can unlock added value while safeguarding against potential risks, ensuring resilience and success in today’s dynamic business environment. 

Trust Your Supplier (TYS) is a Small, Minority, and Woman-owned business with a global reach offering an innovative blockchain-based solution for supplier and risk management to large and mid-size enterprises. By harnessing the immutability of the blockchain, TYS ensures daily monitoring, and historical, predictive, and prescriptive risk insights, enabling trusted data exchange and workflow automation beyond traditional boundaries. This distributed ledger technology fosters transparency, efficiency, and empowerment for businesses to manage suppliers and mitigate risks effectively. 

Top 5 Regulatory Compliance Issues Facing Financial Services in the Next 5 Years

by Michelle Armstrong, TYS Global VP of Value Solutions Consultant and Nick Picone, TYS VP of Advisory Practice

In today’s swiftly and sometimes frantically evolving financial landscape, the banking sector faces an array of complex regulatory challenges. From environmental sustainability and cybersecurity to operational resilience and financial integrity, banks must navigate a labyrinth of compliance issues critical to their success and sustainability. Amidst this dynamic environment, innovative solutions like Trust Your Supplier (TYS) are emerging as key enablers, offering banks an efficient and secure way to manage supplier due diligence and compliance.  

This blog delves into the top five regulatory compliance issues facing banks in the next five years, highlighting how technologies such as TYS and strategic partnerships with entities like Moody’s, RapidRatings, EcoVadis, and Dun and Bradstreet can play a transformative role in meeting these challenges. We will explore the complexities of each regulatory area and how leveraging TYS can aid banks in complying with these evolving requirements and gaining a competitive edge in the banking industry. 

  1. Climate Change and ESG (Environmental, Social, and Governance):

OCC and Global Regulatory Frameworks: The Office of the Comptroller of the Currency (OCC) in the United States, alongside global regulatory bodies, are increasingly focusing on how banks address climate-related financial risks. This includes the development of risk management frameworks that incorporate climate-related risks in their lending and investment practices. 

ESG Compliance: ESG compliance involves adhering to standards and regulations related to environmental conservation, social responsibility, and governance ethics. Banks are expected to integrate ESG factors into their operational and strategic decisions. This includes aligning with the EU’s Taxonomy Regulation, which classifies sustainable activities, and adhering to the Sustainable Finance Disclosure Regulation (SFDR) for transparent ESG disclosures. 

  1. Cybersecurity and Data Privacy:

EU’s DORA: The Digital Operational Resilience Act aims to consolidate and upgrade digital operational resilience requirements across the EU financial sector. For banks, this means ensuring their ICT (information communication technology) systems and tools are resilient against cyber threats. DORA also emphasizes the importance of robust risk management frameworks and regular testing of ICT systems. 

Data Privacy Regulations: Banks need to comply with various data protection laws like the General Data Protection Regulation (GDPR) in the EU and the California Consumer Privacy Act (CCPA) in the United States. These regulations mandate stringent data handling practices and grant individuals greater control over their personal data. 

  1. Artificial Intelligence and Fintech:

Regulatory Focus on AI and Fintech: Banks using AI and fintech solutions must ensure these technologies comply with existing and upcoming regulations. This includes addressing algorithmic bias, maintaining transparency in AI-driven decisions, and ensuring the security and privacy of customer data. 

Sub-Contracting and Vendor Management: Under DORA, banks must manage the risks associated with outsourcing and sub-contracting technology services. This includes ensuring that third-party providers comply with the same operational resilience and data protection standards as the banks themselves. 

  1. Operational Resilience and Business Continuity:
  • DORA’s Emphasis on Operational Resilience: DORA requires financial entities, including banks, to establish and maintain effective and comprehensive strategies and processes to ensure operational resilience. This includes responding swiftly to, recovering from, and adapting to ICT-related disruptions. 
  • SOX and Financial Reporting Integrity: The Sarbanes-Oxley Act of 2002, a result of corporate scandals like Enron and WorldCom, focuses on enhancing the accuracy and reliability of corporate financial disclosures. Banks must ensure that their financial reporting processes are transparent and free from fraud, which is a part of maintaining operational resilience. 
  1. Anti-Money Laundering and Combating Financial Crime:

Bank Secrecy Act (AML & CFT): The Bank Secrecy Act, along with Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) laws, requires banks to monitor and report activities that might indicate money laundering or terrorist financing. This includes maintaining proper records of transactions, filing reports for suspicious activities, and implementing robust customer due diligence (CDD) measures. 

Global AML/CFT Compliance: The regulatory landscape for AML and CFT is global, with banks needing to comply with international standards set by bodies like the Financial Action Task Force (FATF) and local regulations in their jurisdictions. 

Cross-Cutting Themes and Compliance Strategies: 

  • Technology Investment: To comply with these diverse and complex regulations, banks must invest in advanced technologies like AI, machine learning, and blockchain for better risk management, transaction monitoring, and reporting. 
  • Training and Culture: Cultivating a culture of compliance within the organization is crucial. This involves regular employee training on compliance topics, ethical conduct, and awareness of the legal implications of non-compliance. 
  • Proactive Risk Management: Banks should adopt a proactive approach to risk management, continuously assessing and updating their compliance programs to adapt to new regulations and evolving risks. 
  • Stakeholder Engagement: Engaging with regulators, industry groups, and other stakeholders is vital for staying ahead of regulatory changes and understanding expectations. 
  • Audit and Assurance: Regular internal and external audits are necessary to ensure compliance with SOX, AML/CFT laws, and data privacy regulations. 

Integration of Trust Your Supplier in Banking Industry Compliance 

As banks navigate the complex regulatory compliance landscape, especially in areas like supplier due diligence, technologies like Trust Your Supplier (TYS) play a pivotal role. TYS, a blockchain-based platform, revolutionizes how banks manage and verify supplier information, ensuring compliance and enhancing operational efficiency. 

Strategic Partnerships Enhancing Compliance and Due Diligence: 

  • Dun and Bradstreet: Utilizing Dun and Bradstreet’s vast database enhances banks’ ability to conduct thorough background checks, assess credit risk, and maintain compliance with AML and CFT regulations.  
  • EcoVadis: EcoVadis brings sustainability ratings into the mix, enabling banks to align with ESG compliance by evaluating their suppliers’ environmental and social impact. 
  • Moody’s: Collaboration with Moody’s provides banks access to critical credit ratings and risk assessments, which are integral for evaluating suppliers’ financial stability and risk profiles. 
  • Rapid Ratings: Partnering with Rapid Ratings allows banks to leverage financial health data, offering a comprehensive view of supplier risk, which is vital in assessing small and medium-sized enterprises. 

Leveraging TYS for Enhanced Compliance: 

Automated Compliance Questionnaires: TYS simplifies the compliance process by providing automated questionnaires tailored to banking industry standards, including SOX, GDPR, and DORA. This automation ensures thorough and consistent supplier vetting, which is crucial for regulatory adherence. 

Blockchain Advantage: The blockchain foundation of TYS offers unparalleled transparency and security in supplier information management. This feature is particularly beneficial for complying with data privacy laws and mitigating cybersecurity risks. 

Operational Resilience: By streamlining supplier information management, TYS directly contributes to the operational resilience of banks. It provides a robust framework to manage supply chain disruptions, a key aspect of business continuity planning under regulatory frameworks like DORA and OCC regulations. 

TYS: A Tool for Proactive Compliance Strategy 

Incorporating Trust Your Supplier into the banking industry’s compliance strategy offers a proactive approach to meeting regulatory demands. It not only assists in complying with current regulations but also positions banks to quickly adapt to future changes in the regulatory environment. The platform’s integration with strategic partners like Moody’s, Rapid Ratings, EcoVadis, and Dun and Bradstreet further enriches its capability to offer comprehensive, multi-dimensional supplier assessments. This integration is crucial for banks aiming to stay ahead in the compliance game, ensuring they are reactive and forward-thinking in their compliance and operational strategies. 

In the ever-evolving regulatory landscape of the banking industry, platforms like Trust Your Supplier are not just tools but essential allies. They enable banks to manage supplier risks effectively, ensure compliance, and maintain operational resilience. As we continue to explore the detailed aspects of banking regulations in our upcoming posts, the role of innovative solutions like TYS in aiding compliance and enhancing due diligence processes will be a recurring theme.  


Over the next week, we will dive deeper into these topics, unraveling the complexities and nuances of OCC regulations, DORA, the Bank Secrecy Act, data privacy laws, and SOX. We’ll examine how these regulations will shape banking practices’ operational, strategic, and ethical dimensions. Each post in this series will offer in-depth insights and practical guidance, helping banks and financial professionals navigate these challenges effectively. Stay tuned as we dissect these themes individually, providing a clearer understanding of what lies ahead in the dynamic world of banking regulation.