The One about Bribery & Corruption

The One Where Lise and Natasha Explain Modern Slavery

Modern slavery is one of the most under-enforced areas of corporate compliance and the legal landscape is moving fast. In this episode, Sylwia and Amritha are joined by two leading practitioners to unpack what companies are actually required to do, where the frameworks fall short, and why a clean audit is no longer proof of a clean supply chain. S2E8 brings in two specialist guests for a deep dive into modern slavery — picking up where the trafficking episode left off. Lise Smit is a Business and Human Rights Adviser at Norton Rose Fulbright LLP, advising on human rights due diligence, supply chain risk management, and sustainability reporting under the UN Guiding Principles. She led the European Commission study that formed the basis for the EU CSDDD. Natasha Martin is Director of Product at Ethixbase360, with close to 20 years in regulatory technology spanning modern slavery, human rights, AML, and counter-terrorist financing, specialising in translating complex regulatory requirements into practical, technology-enabled solutions. Together, they cover the key legislative frameworks — UK Modern Slavery Act, EU CSDDD, EU Forced Labour Regulation, and the US UFLPA — with a focus on what's working, what isn't, and what's still missing. The conversation moves through supply chain mapping beyond Tier 1, the limits of social audits, emerging technology including AI and satellite imagery, and how HRDD findings escalate into financial crime referrals. Sponsors We’re proudly independent - but we partner with companies who share our passion for smarter due diligence and investigations. This episode is exclusively sponsored by Ethixbase360: Confident decisions, powered by people and platform Market-leading third-party risk management platform combining smart automation, expert-led due diligence, and responsive support to deliver a clear, connected view of global third-party risk. Deploy a third-party risk management program that grows with your organization – from a single function to enterprise-wide coverage. Empower faster, smarter decisions with the data and insights trusted by global leaders. Gain a unified, real-time view of your third-party risk landscape — with built-in insight, and audit readiness. Maximize efficiency and performance with dedicated, expert support designed to save time, reduce costs, and strengthen your program. Learn more at ethixbase360.com. Subscribe & Follow Subscribe, leave a review, and share with anyone in risk, compliance or investigations — or anyone who thinks that a clean audit means a clean conscience.

The One Where We Explore Human Trafficking

In this episode, Sylwia and Amritha examine trafficking in human beings as a predicate offence — what it actually is, how its financial footprints appear in banking and payments data, and why it concerns everyone from transaction monitoring analysts to supply chain compliance teams. You'll learn: why trafficking is often financially detectable before it is criminally provable — and why that makes financial institutions the front line, not a supporting act what Suspicious Activity Reports are, why they matter, and why in practice the system is both essential and badly broken the difference between what AML teams are expected to do (spot and report) and what corporate compliance teams are expected to do (spot, investigate, and actually fix it) ten recurring financial typologies — from funnel accounts and smurfing to debt bondage repayment patterns and third-party wage control — that regulators associate with trafficking and exploitation how to translate those typologies into transaction monitoring scenarios without crossing into the trap of thinking you are identifying victims rather than flagging suspicious financial behaviour why the Libya slave trade, the Yemen trafficking camps, and the Dyson supply chain case all point to the same thing: the money moves before the crime is proven, and following it is how investigators make a difference Resources & links: https://www.unodc.org/unodc/en/data-and-analysis/glotip.html https://www.ohchr.org/en/professionalinterest/pages/protocoltraffickinginpersons.aspx https://washingtoncentre.org/rico-and-rescue-how-legal-tools-can-disrupt-human-trafficking-networks/ Cases & Examples https://www.hrw.org/report/2014/05/25/yemens-torture-camps/abuse-migrants-human-traffickers-climate-impunity https://www.theguardian.com/law/2026/jan/22/uae-ordered-to-pay-260000-to-trafficking-victim-exploited-by-diplomat-in-london https://www.amnesty.org/en/latest/news/2025/05/saudi-arabia-migrant-domestic-workers-face-severe-exploitation-racism-and-exclusion-from-labour-protections/ https://www.bbc.co.uk/news/uk-politics-65987378 https://www.bbc.co.uk/news/articles/cj6pdxj1dw1o https://www.theguardian.com/world/2023/jun/13/i-trusted-him-human-trafficking-surges-in-cyclone-hit-east-india https://www.icij.org/investigations/trafficking-inc/about-trafficking-inc/ https://www.bbc.co.uk/news/uk-england-essex-55765213 https://www.ihrb.org/latest/the-dyson-case-a-landmark-moment-for-business-and-human-rights Sponsors: We’re proudly independent but we partner with companies who share our passion for smarter due diligence and investigations. Inquirify is a global risk intelligence partner providing due diligence, OSINT, GSOC and investigative support across complex jurisdictions. Our philosophy is simple: Verify before you trust. We provide clear, actionable insights to protect your business and support growth. Find out more at: https://www.inquirify.net JAM Insights delivers human‑driven intelligence you can’t get from screens alone. When conventional OSINT and AI fall short, JAM taps into trusted local sources, on‑the‑ground research, and deep industry assessments to identify hidden risks, reputational red flags, and jurisdiction‑specific issues that matter for high‑stakes due diligence, compliance, and strategic decision‑making. With tailored insights spanning key regions and strict confidentiality, JAM helps clients see what others overlook and act with confidence Find out more:.https://www.jam-insights.com Subscribe & Follow Subscribe, leave a review, and share with anyone in risk, compliance or investigations — or anyone who thinks human trafficking is someone else's problem to solve.

The One about Bribery & Corruption

In this episode, Sylwia and Amritha examine bribery and corruption as predicate offences — the crimes that generate dirty money long before a suspicious transaction alert fires or a sanctions designation lands. They explore why understanding the law is only the starting point, and why geopolitics, local practice, and cultural context are just as essential for anyone working in AML or corporate compliance. You'll learn: why bribery is the only predicate offence with its own dedicated international treaty architecture — and why it made corporate "failure to prevent" a criminal matter before any other crime did how the Unaoil case illustrates the gap between who pays fines and who actually recovers the proceeds of crime what Odebrecht — a Brazilian construction giant that created an entire internal division dedicated to managing bribes across twelve countries — reveals about industrialised corporate corruption and the extraterritorial reach of US law how the Adani case shows what happens when political proximity, offshore structures, and state contracts converge — and why the FCPA pause matters most in precisely these politically sensitive situations why AML and ABC compliance teams are looking at the same risk from opposite ends, and why that gap is exactly where schemes live the three Cs — conduct, connections, and context — and what red flags look like in practice what the UK's December 2025 Anti-Corruption Strategy and new Five Eyes indicators guidance mean for transaction monitoring and third-party due diligence Resources & links: https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/ https://www.occrp.org/en/news/us-ditches-key-anti-bribery-law-critics-warn-of-global-corruption-surge https://www.occrp.org/en/news/german-ex-mp-convicted-in-azerbaijan-bribery-scandal https://www.politico.eu/article/belgian-authorities-mixed-up-eu-lawmaker-with-namesake-huawei-bribery-probe/ https://eucrim.eu/news/high-risk-areas-of-corruption-in-the-eu-in-depth-report-highlights-six-vulnerable-sectors/ https://www.mofo.com/resources/insights/260114-top-10-international-anti-corruption-developments-for-december-2025 https://www.theguardian.com/us-news/2026/feb/02/trump-uae-crypto-deal https://www.aljazeera.com/economy/2026/5/18/us-drops-fraud-charges-after-billionaire-adani-pledges-10bn-investment https://www.bbc.co.uk/news/business-39194395 https://whistleblowerjustice.net/blog/birth-of-the-fcpa-this-bribery-is-positively-bananas/ Sponsors: We're proudly independent but we partner with companies who share our passion for smarter due diligence and investigations. The Search Group - Every Decision Carries Risk. Managing it requires more than surface-level checks. At The Search Group (TSG), we deliver specialist due diligence and risk intelligence through a global network of expert hubs, combining deep local insight with global perspective. For over 15 years we have supported clients across 100+ jurisdictions with Compliance reviews, Pre-transaction due diligence, Investigations and Ethics advisory. Our tailored research transforms complexity into clarity and risk into opportunity – empowering confident, informed decisions. Discover how TSG can support your next big move at www.thesearchgroup.com. Subscribe & Follow Subscribe, leave a review, and share with anyone in risk, compliance or investigations — or anyone who thinks bribery is just an envelope under a table.

The One with Terrorist Financing

In this episode, Sylwia and Amritha examine terrorist financing — how money moves to support terrorist organisations, why it differs from money laundering, and how ordinary companies can become caught in the middle. You’ll learn: why terrorist financing is about purpose, not just source of funds, how clean money can become criminal depending on where it goes why terrorist financing and money laundering are linked but fundamentally different, how charities, informal value transfer systems, trade and digital payments can be misused, what the Lafarge, Chiquita and Ericsson cases reveal about corporate exposure, what investigators, AML teams and due diligence professionals should look for when assessing terrorist financing risk. Resources & links: FATF – Terrorist financing: https://www.fatf-gafi.org/en/topics/terrorist-financing.html UN Convention for the Suppression of the Financing of Terrorism: https://treaties.un.org/doc/db/Terrorism/english-18-11.pdf DOJ Lafarge guilty plea: https://www.justice.gov/opa/pr/lafarge-pleads-guilty-conspiring-provide-material-support-foreign-terrorist-organizations ICIJ Ericsson Files: https://www.icij.org/investigations/ericsson-list/ DOJ Chiquita case: https://www.justice.gov/archive/opa/pr/2007/March/07_nsd_161.html https://www.corporatecomplianceinsights.com/fcpa-changes-terrorist-designations-cartels-latin-america/ https://edition.cnn.com/2010/WORLD/americas/02/12/colombia.chiquita.farc/?hpt=T2 https://www.ecchr.eu/en/case/lafarge-in-syria-accusations-of-complicity-in-grave-human-rights-violations/ https://www.bbc.co.uk/news/articles/crl1441816po Sponsors: We’re proudly independent but we partner with companies who share our passion for smarter due diligence and investigations. Inquirify is a global risk intelligence partner providing due diligence, OSINT, GSOC and investigative support across complex jurisdictions. Our philosophy is simple: Verify before you trust. We provide clear, actionable insights to protect your business and support growth. Find out more at: https://www.inquirify.net Subscribe & Follow Subscribe, leave a review, and share with anyone in risk, compliance or investigations or anyone who thinks terrorist financing is a remote problem.

The One on CSAM

⚠️ Content Warning: This episode discusses child sexual abuse material (CSAM), online child sexual exploitation, trafficking, and related investigations. Some listeners may find the subject matter distressing. Please take care while listening. In one of the most difficult — and important — episodes we’ve produced, Amritha and Sylwia examine the financial systems, investigative methods, and compliance failures connected to child sexual abuse material (CSAM) and online child sexual exploitation. The episode begins with the takedown of Welcome to Video, once the world’s largest known dark-web CSAM marketplace, uncovered after IRS investigators followed suspicious Bitcoin flows. From blockchain forensics and crypto tracing to dark-web infrastructure and live-streamed abuse, the episode explores how financial intelligence increasingly sits at the centre of these investigations. You’ll learn: why the term “CSAM” matters, how online child exploitation operates financially, the role of crypto and payment systems and the rise of AI-generated abuse material, investigative techniques used by law enforcement, and what the Jeffrey Epstein banking failures reveal about culture, ethics and compliance. Resources & links: BBC World of Secrets (The darkest web): https://www.bbc.co.uk/sounds/play/w3ct8yw5 https://jacobin.com/2026/02/fbi-epstein-kuchner-whistleblower-silenced https://www.acams.org/en/news/ex-aml-officer-claims-deutsche-fired-her-after-she-flagged-epstein-transactions https://www.bbc.co.uk/news/world-50073092 https://www.icmec.org/press/new-report-examines-cryptocurrencys-role-in-online-child-sexual-exploitation/ https://www.ofcom.org.uk/online-safety/protecting-children/child-sexual-abuse-material-csam-results-from-a-survey-of-perpetrators https://eucrim.eu/news/operation-alice-exposes-fraudulent-csam-platform/ https://www.europol.europa.eu/media-press/newsroom/news/global-crackdown-kidflix-major-child-sexual-exploitation-platform-almost-two-million-users If you or someone you know needs support or wants to report child exploitation material, reporting resources include the NCMEC CyberTipline (US), the Internet Watch Foundation (UK), and INHOPE’s global hotline network. Sponsors: We’re proudly independent but we partner with companies who share our passion for smarter due diligence and investigations. JAM Insights delivers human‑driven intelligence you can’t get from screens alone. When conventional OSINT and AI fall short, JAM taps into trusted local sources, on‑the‑ground research, and deep industry assessments to identify hidden risks, reputational red flags, and jurisdiction‑specific issues that matter for high‑stakes due diligence, compliance, and strategic decision‑making. With tailored insights spanning key regions and strict confidentiality, JAM helps clients see what others overlook and act with confidence Find out more: https://www.jam-insights.com Inquirify is a global risk intelligence partner providing due diligence, OSINT, GSOC and investigative support across complex jurisdictions. Our philosophy is simple: Verify before you trust. We provide clear, actionable insights to protect your business and support growth. Find out more at Inquirify.net Subscribe & Follow Subscribe, leave a review, and share with anyone in risk, compliance or investigations. The more people having these conversations, the harder these networks become to ignore.