SPEAKER_00 0:03

Welcome to episode six of Voices in Compliance. Uh, I'm Jason Thomas, co-founder of Alexander Barnes. Today we are lucky enough to have someone I got to know very well over the past year, Deirdre Murphy. She is VP of Anti-Fanancial Crime and Compliance, uh, UK entities for BitPanda. Welcome, Dee.

SPEAKER_01 0:20

Thank you, Jason. Pleasure to be here. I'm delighted to see you again.

SPEAKER_00 0:23

Thank you, you too. I always ask everyone how was your journey in?

SPEAKER_01 0:26

Not too bad. I mean, it's obviously a little bit warmer in London today, which is nice. Although, and I think there's still unfortunately a little bit of uh overhang from the tube strides last week, but uh but not too bad. Thanks.

SPEAKER_00 0:37

Uh do you have to travel far?

SPEAKER_01 0:38

No, just from Highgate, so just down the road and uh uh walked up in Farrington.

SPEAKER_00 0:42

Lovely. Well, good look. Great to have you on. Thanks for coming in. I think um there'll be a lot of people listening and be really interested to uh hear from you. Um BitPanda, you see them everywhere at the moment. I'm a big football fan, obviously sponsoring Arsenal. They seem to be doing some really big things. I think it'd be good to kind of get an overview about your role and maybe what they're doing at the moment.

SPEAKER_01 1:00

Yeah, fantastic. Um, yeah, certainly. We are doing a lot more in the UK than we ever have before. So, BitPanda, for those of you who don't know, um, is a primarily European uh crypto platform um really trying to globally expand here at the moment. So we're looking in the UK, we also have some entities in the UAE which are registered with VARA. Um, but of course, we have founded in Austria, so we've got a number of different entities in Austria, both on the crypto side and also on the MiFID compliance and on the payments, and we also have a couple of entities in Germany, so really uh quite a global player or trying to be a global player in the crypto space. And as you say, we do a lot of sponsorship with some sports teams, including Arsenal, so really trying to get our name out there in the UK at the moment.

SPEAKER_00 1:45

Awesome. You're a football fan?

SPEAKER_01 1:47

I am, of course. I'm a big Arsenal fan now, definitely. Yes, yes.

SPEAKER_00 1:51

And what about yourself? Are you working on anything yourself exciting in terms of projects at the moment?

SPEAKER_01 1:55

So a lot of exciting projects, as you can imagine, at the moment. Um, we're being really kept busy globally as a firm from a compliance perspective with Maker, obviously, um, now that that's come in. On a personal level, of course, we're looking at the UK expansion, we're looking at the new FISMA regime that will come in for crypto uh towards the end of 2027. But the gateway for applications opens for that on the 30th of September this year. So everyone's going to be rushing to complete that. Um, so yeah, and of course, travel rule compliance is a big one that we'll talk about later, I'm sure. Um, and also the AML regulation for next year. So all go.

SPEAKER_00 2:30

Yeah, all busy, definitely. And what about financial crime, I guess, within crypto? Obviously, I guess it's a lot different than traditional banking. Be keen to get your views on that.

SPEAKER_01 2:39

Yeah, I think um, I think sometimes there's a still, you know, misperception around financial crime and crypto. And I think sometimes it's unfairly perceived to be more risky. I think it's a lot of it's around the type of risk that you see and the type of things that we're looking at as different to what we'd look at in traditional finance. Um, I myself have spent a long time in traditional finance before going over to crypto, so I have a good idea that when you're looking in traditional finance, for example, I was in Morgan Stanley, looking at the types of customers you have, potentially complex structures, uh, that type of thing. Um, whereas in crypto, yes, we're looking at customers and customer risk, but we're really looking at a lot of transaction activity, where the crypto is going, where is Viet going and coming from, of course. So it is it is a little bit different, but ultimately the principles are the same.

SPEAKER_00 3:26

Yeah, no, makes sense. And it's good that you've worked in both. I think you can give a good insight into both. Do you think crypto's uh do you think it's getting treated in a different way now? I think people are taking it more seriously than maybe a year, two years ago.

SPEAKER_01 3:37

Absolutely. Um, it is becoming more prevalent. Um, I think it is becoming something that you know the every person is looking at. Um, even looking at the FCA's data regarding how many people own crypto, we see new data coming out every year, and you can see more and more people having exposure to crypto. So, with that, it it naturally goes to a a direction whereby, you know, everyone's going to be coming looking at it, which means that it is going to be more regulated in the coming years, which I think is a good thing ultimately.

SPEAKER_00 4:08

For people who aren't in this like industry, like I'm like friends of mine, they all seem to think like crypto is like really um, you know, there's there's there's massive, massive problems within financial economy. It's really focused on crypto more than other areas. Would you say it is, or do you think that's unfair?

SPEAKER_01 4:22

I think it's a little bit unfair still. I think I can understand why the perception is there historically. Um, but I don't think it is a a fair perception now. But I can understand why. I mean, ultimately, most people still have fiat, right? The most people still transact with fiat. Now, crypto is doing a lot to change that. There's a lot of talk about financial freedom. Um, so you know, when crypto becomes ubiquitous, maybe you could say they're equivalent. But ultimately, in terms of money laundering and terrorist financing, you know, we're still looking at TradFi more than crypto in terms of the actual overall global exposure. Um, and when you actually look at the data that's coming out from you know the companies like Elliptic and others, it's estimated that less than 1% of funds are actually listed in the crypto space, right? So trillions and trillions are still laundered elsewhere through the field space. So um it's more a perception. I think it's uh it's an unfair perception. I can understand it, I think historically. Exactly. And I think crypto gives us really interesting opportunities with blockchain analytics technology to actually have better traceability than TradFi. So yeah.

SPEAKER_00 5:29

Are there any sort of myths you'd like to debunk within the space within financial crime or crypto, if you could?

SPEAKER_01 5:33

A lot of people suggest that crypto is completely anonymous and untraceable. I think that's one of the biggest myths. Okay. Um and actually, this is one of the things that really got me interested in crypto at the start before I went into it, was around looking at blockchain analytics tools. And we've got amazing tools out there where you really can trace the crypto. Um, you can trace it, in fact, uh, you know, a lot more successfully than you can feat in in many cases. And I think that's a huge myth that needs to be debunked.

SPEAKER_00 6:02

Okay, that's a good answer. And then if you compare crypto crime, financial crime versus traditional finance, like how would you compare the two?

SPEAKER_01 6:10

Um I mean, they are slightly they are slightly different to a certain extent. A lot of let's say TradFi, when we look at financial crime, is around potentially hiding structures, potentially going into things like predicate offences like tax evasion, for example, or uh or other types of predicate offence. In crypto, a lot of the financial crime was actually potentially sends directly to illicit activity, illicit markets, dark net markets. Um, and and you don't necessarily see the same thing in TradFi, although you could from and the cash side of things, certainly. But that's what we see. And and of course, like I say, that's actually traceable. Um, we have these amazing blockchain analytics tools, and they find out where these illicit wallets are and ultimately um be are able to actually see direct dark net exposure and sometimes indirect darknet exposure.

SPEAKER_00 6:59

Do you think the criminals are getting a bit more clued up into the market now? Is it are they finding different ways to do things? They're always seem to be evolving.

SPEAKER_01 7:06

Yes, I think I think that's the nature of the beast, not just of crypto with Tradfy as well. I think criminals are sadly always one step ahead of us and we we're always playing catch-up. But again, we look at really interesting typologies. So it's super important, I think, for folks in my industry to continue to educate themselves on different typologies, try to look at the latest scams and schemes and say, okay, well, are we preventing that? Doing lessons learned when we see these things come into play so that we can hopefully catch up, but we are still playing catch up to a certain extent.

SPEAKER_00 7:40

Is there anything that keeps you up at night in terms of your your actual role in terms of what could happen or people doing things that could you know affect your role?

SPEAKER_01 7:48

I try not to keep up till too late at night. Yes, of course. There's loads, there's loads of things. I think mostly around maybe some challenges with my role, um, some challenges around implementation of regulatory requirements probably is more difficult than the actual financial crime element. Because I actually think that from uh the the use of the transaction monitoring that we have, the use of blockchain analytics is is quite quite good at actually catching this potential activity. And then we do the right thing and report it to the authorities and offboard those users. Um, so I'm not as worried about that than I am worried about keeping up to date and you know constantly keeping at pace with regulatory requirements.

SPEAKER_00 8:30

Okay. Moving on to the UK financial uh promotions regime, have you seen a big shift in that area?

SPEAKER_01 8:36

Uh indeed, yes. So, yes, uh, with us, with BitPanda, we've really only come into the UK and try to establish our UK presence on our entity post the implementation of the financial promotions regime, which has meant that we have had to do a lot more, we've had to make a lot of changes to our platform and how it's actually seen in terms of the user experience will look different in Europe to the UK. So if you were applying and going into BitPanda and you were using potentially a VPN, showing you were in another jurisdiction, you'd have a completely different view. Um, I think ultimately it it is uh, you know, has the best intentions around consumer protection and consumer duty, but of course it just means that it's a much higher uh uplift from a compliance perspective so that we can stay on the right side of everything and the laws. Any other big challenges w regarding it or yeah, I think um it's potentially difficult for users. Okay. I think one of the things that is quite uh challenging both for firms and for users are things like the 24-hour cooling off period and appropriateness assessments. And look, I think I can understand why these are requirements. It really makes a lot of sense for consumer protection, um, especially when we consider crypto to be a higher risk investment overall, given volatility. Um, so of course, we need to make sure that we are protecting those consumers at the end of the day, and that's the FCA's intention. However, I think the challenges that we see, particularly given we are a new player in the market, we want to go into customer acquisition. It's a it's it's a disincentive to a certain extent for customers potentially moving from one platform to another because they will need to go through all of this, these requirements again. Um, and then of course, for example, when the markets are good, when there is good sentiment, there is a blocker for immediate investment, which you don't necessarily have with other types of investment.

SPEAKER_00 10:24

Are you guys finding challenges with the margins? Is that becoming uh a challenge for BitBander?

SPEAKER_01 10:29

Margin trading, um, if that's what you mean, is is uh a really interesting area. And actually it's something that we started doing in Europe for crypto before we started doing it in the UK. It's something that um is recently just been launched in the UK with a lot of um coordination um on my part and on my colleagues' parts with the FCA. So we've worked very, very closely with them to ensure that what we're bringing out is a product that you know that they don't have ultimately objections to or blockers to. Um, but it does look different in the UK than than the Europe. And a lot of that is to do with the FCA's focus on consumer protection. So the challenges there are to really ensure that what you're allowing your customer to enter into is a product that's suitable for them and that they really, really understand the risks. So therefore, it means additional warnings, additional appropriateness assessments, for example, and and lower leverage. The the leverage amounts, you know, it's important that we um ensure that we have mechanisms in place as well to protect the consumer to stop losses, which we have done.

SPEAKER_00 11:32

Yeah, so a lot of them, a lot of research for them to do as well to get clued up. It's not all on you guys, it's uh both sides, really.

SPEAKER_01 11:38

Definitely, it's like a back and forth conversation, and um, it's also about having, I think, really open, honest conversations with the regulator about uh what we intend to do, how we intend to protect consumers, and you know, we we I think we have a good relationship and uh work well in terms of ensuring that we're doing the right thing.

SPEAKER_00 11:57

Do you think the UK rules have made the market safer, or what's your actual view on that point?

SPEAKER_01 12:01

Do you mean do you mean for consumers? Um I think yes, to a certain extent, absolutely. Um, I think in some cases there are blockers. One of the things that I would say is um while the the UK rules are in place very much aimed at uh protection of consumers, I think potentially it is something that we want to revisit as a firm, and and we're not the only one in the space, some of our peers are doing this. We do want to continue to have a look at the label of crypto as a restricted mass market investment because of all of the additional frictions potentially in place for our customers. I think it's super important that we continue to protect the customers and put those protections in place, but we also need to make sure that it's practical and works on an ongoing basis. So we're we're you know looking um at this particular area in light of the new FISMA regime to see what's the right balance because I think balance is important at the end of the day.

SPEAKER_00 12:57

Makes sense. What about Mika? Hot topic everyone's talking about or has been for the past year or so.

SPEAKER_01 13:02

Indeed, yeah, it's been a super busy year, as you can imagine, uh, in the regulatory space. We have actually uh acquired several Mika licenses, would you believe? Uh and uh that's been something that SpitPand has been really, really busy with with it for the last year. Of course, there's no Mika in the UK just yet, but we'll have the Mika equivalent come in, FISMA. And so a lot of the work we'll be doing over the next while is on implementation of that, but also you know, looking at the differences in the regimes.

SPEAKER_00 13:30

Seven, that's amazing. What locations are you able to say the locations they're in?

SPEAKER_01 13:34

Uh yes, at the moment we have uh Mika licenses in Austria and Germany. We also have one in Malta at the moment.

SPEAKER_00 13:40

Brilliant. Yes. Hard to get or? Of course. Yeah.

SPEAKER_01 13:44

No, I think you know, one one thing I would say, yes, of course, uh licenses are there's a lot of work goes into a lot of work goes into all licenses. I think one thing that's interesting in our industry and in our our role in particular is that a lot of people see the license as the finish line. Yeah. And it's not the start line, right? You know this from your marathon the other day. Yeah, I did. So, you know, it's it's kind of the start line of the marathon. You you've done all the it's getting it's all the training, right? It's all the prep. But ultimately then the hard work starts, complaints, and you need to make sure that you're building that trust or the regulators on an ongoing basis. So um yeah, a lot of work just continues, shall we say? I can see it though.

SPEAKER_00 14:27

You can kind of see all that hard work get into the get the license obviously very difficult, and then kind of done it so it's like breathe, but actually the work does start there. Exactly. Your focus obviously on the UK. Do you feel how do you feel about the UK versus Europe though? Is the UK potentially falling behind Europe? Do you think there's challenges for the UK?

SPEAKER_01 14:43

I don't think it's falling behind Europe. I mean, arguably, Mika has come in before and the UK equivalent regime has not come in yet. Um, but I would say that the UK has done a huge amount of work in the U over the last 18 months, in particular in preparing for that regime. Uh working with firms, we have an amazing policy person at BitPanda who's done a lot of work and back and forth with our consultation papers. Um, so the the the FCA and and the UK regime, they really are trying to work with firms to get to a point where it all makes sense and and and works for the market.

SPEAKER_00 15:15

Good. I know you're not a politician, but if you were speaking to the UK government, is there anything you would kind of advise from a UK standpoint?

SPEAKER_01 15:23

I think keeping crypto at the forefront of policy makers, I think is super important. They have been doing that, I have to say. Um, more consistency potentially, uh, you know, across across different regimes and jurisdictions is something that uh is welcomed by all.

SPEAKER_00 15:40

Good. Overall, it seems to be taken more seriously. I think there's there's more involvement within crypto and stable coins everywhere, and I think people generally are seeing a change in it. Would you say that's fair?

SPEAKER_01 15:49

Yeah, I think so. There's definitely more willingness to to invest than there was before. There's a little bit of stability in the market, not with all assets, not with all coins, and but certainly on the big ones, uh, those that have the highest market cap, those that have the best known names. Um, and that's a good thing.

SPEAKER_00 16:05

Okay, good. What about the travel rule? People I speak to in the industry saying that's still a challenge. Is that something you're seeing?

SPEAKER_01 16:11

Travel rule is definitely still a challenge. Um, we we we've we've had lots of challenges with travel rule. Up to date, we continue to have ongoing challenges. I would say that we're not unique. It is definitely not unique to any particular firm. This is an industry-wide issue. Okay. Um, the biggest issues for now are interoperability still, um, because there is no one source of truth or system that's used by all firms, which is a problem. Um, and then there's a sunrise issue, the fact that some jurisdictions still don't quite have the travel rule in place just yet. Um, so it's something we're continuously navigating. Um, but uh yeah, a challenge we're accepting and uh on an ongoing basis.

SPEAKER_00 16:53

And what's the most challenge that's impacting that at the moment? Is there something in particular that's really impacting it?

SPEAKER_01 16:58

I think what's really difficult for for me and for um probably for most firms as well is the expectations around self-hosted wallets. Okay. Um, because the rules do require certain certain aspects of verification of self-hosted wallets, which makes sense. But how do you actually do that? There is no one system, there is no one source of truth for doing that, there's no consistency. And that also means that potentially some jurisdictions that all have the same requirements have a competitive advantage. Um, and we want to get away from that, hopefully.

SPEAKER_00 17:30

And if you're trying to build compliance frameworks and the regulators are intervening all the time, is that difficult to then build?

SPEAKER_01 17:36

Um, yes, to a certain extent. Um, I think when you're building compliance frameworks, what we're trying to do is potentially grab, have global consistency, um, have a global framework, have global minimum standards. I think that is the best thing to do for us personally. Um, but there are, of course, differences per jurisdiction. And when one regulator comes out with something that's slightly different to another, that of course is challenges. But one thing that we do try to do as well in BitPanda is we have sometimes bespoke approaches for KYC, for example, because we're trying to be also client-centric and customer friendly. So if we were to go to the highest standard across all jurisdictions, well, that you know, potentially could impact customers in one jurisdiction poorly. Um, so we do have slightly different, different approaches, but on a policy level, consistency where possible is my is my key.

SPEAKER_00 18:25

Awesome. What about the travel? Is that actually made a difference to the financial crime? Is there any like sort of data to show that that's reduced because of the travel rule, or you're not at that point yet?

SPEAKER_01 18:34

I don't think we're quite at that point yet. Um, and I maybe, maybe I I'm wrong here, so I would be corrected if I am, but I still see the interoperability as a big issue. Okay. The fact that we cannot have 100% compliance just yet, um, and that isn't definitely not uh not unique to BitPander or any particular firm. Um, and that just makes it quite challenging to actually be able to show the success rate. I think I can understand the principles behind it, I can understand why it in the future would potentially have uh an impact. I just think for now we're we're we're not just at that level. But give it a few more.

SPEAKER_00 19:12

A few minutes it'll definitely move. Yeah.

SPEAKER_01 19:14

Yes, I hope so.

SPEAKER_00 19:14

And what about juggling kind of like good AML controls with customer experience? Is that hard to manage the two and get them kind of balanced out?

SPEAKER_01 19:22

Definitely. Yeah. And that's something that's you know a contentious issue, I think, a lot of the time and a subject for discussion. Um, we want to have ensure, even in compliance, right? I think there's a myth, right, that compliance people are here to say, no, and here to block the business and here to stop everyone's fun. And that's definitely not the case. And I think, you know, one of the things that we really need to do is work with together and make sure that we're coming to the right results at the end of the day for the customer, but also from a regulatory perspective. That becomes a challenge with KYC and the likes because we don't want to impact the customer, we don't want to upset the customer, we don't want to ask them for data that we're not going to use. In fact, we can't, GDPR, as we all know. So um, so yeah, it is an ongoing, ongoing challenge and issue, um, and it's a balancing act. Uh, I think it's important to ask the questions. We need to get the right questions in order to risk assess customers, but we can frame the way we ask them in the most client-centric way. Um, we can also make sure that we're going out to customers at the right level for periodic refresh, that we're not being overly impactful, that we are only asking for an uplift in data if that's what's required. So lots of different ways of doing it, but uh, I think collaboration with the product and engineering in the first line is the important scheme.

SPEAKER_00 20:35

On that, slightly off topic from maybe what we're going to talk about. I'm interested to speak to people in the industry. What compliance people sometimes can be seen as blockers, as you said. I think it can be very difficult for them to get buy-in. Do you think what do you think the good ones do? Do you think they're kind of building that relationship with internal stakeholders very well to get the buy-in to show they're not a blocker, or what what have you seen in the past?

SPEAKER_01 20:55

Yes, I think so. I'd like to think we do we do that as well. Um, I think it's around coming up with practical solutions and showing that you can be a pragmatic and then you you that it is not a blocker. I think the good compliance folks, first of all, like a lot of compliance is actually education, explaining, discussing the why things are required, because when there's a lack of understanding on that, um, that's not going to work out well. Equally, you don't want a compliance person who's just going to come in and cite regulation. Um, I've I've had people do this in the past, it's not effective. Nobody wants to be cited as sections of the law or regulation to, not even compliance officers, I would say, for the most part. Um so it's around going, well, this is what the law says, but here's how we interpret it. And sometimes it is a conversation around and open to interpretation, what guidance notes say, etc. Um, but what I hope we we can do mostly in the compliance industry is come uh and agree that we can be a trusted partner for the business, work together, and not be a blocker, but find the right way of doing things. So Not to say no, but say not in that way. Let's find the right way.

SPEAKER_00 22:03

Awesome. Any advice you'd give to people who are trying to move into this space, more up and coming in the industry, they're looking to get to senior roles?

SPEAKER_01 22:11

Oh, um advice for compliance folks. Be curious. I think always a curiosity and really having those open conversations. I think empathy is a huge skill as well, right? Like I early on in my career, before I even went into compliance, and I didn't go into this in my bio because it would show my age, but a long, long time ago, I worked in like a middle office and I worked in front office in a brokerage firm. So I think actually sit maybe sitting in the seat with somebody for a day and saying, What's what it's like from your perspective? What are you know the issues that you're getting? Well, where are your blockers? Where are your challenges? Um is is a big thing. And I think having that skill of understanding where the other stakeholders are coming from is a huge thing. Um, and then rather than coming in and going, no, here's the regulation, saying here's here's why it's important. And showing the impact of potentially doing the wrong thing and and having that discussion in a really open way.

SPEAKER_00 23:08

I still think, yeah, being around people and learning and watching is still. I know everyone's trying to move into these remote worlds where everyone just sits at home and doesn't speak to people. Um sadly true. AI's gone crazy. Um is there much change within your remit AI within financial crime? You've seen a lot of AI movement.

SPEAKER_01 23:25

I think there's a huge use case for AI and financial crime. I I think we could do certainly a lot more than than we're currently doing and do it responsibly. Um, I in in terms of our current firm at the moment, we of course have a responsible AI use policy. Um, one of our original founders is absolutely embedded in the AI process and really, really interested, which is fantastic to see. And so we're looking at the use cases. But for for me, I think for compliance and certainly in financial crime compliance, um, transaction monitoring is a huge thing. Transaction monitoring, looking at source of well, source of funds, enhanced due diligence, taking data from potentially large bit sets of of information that you're getting and putting it in a cohesive mannered manner can all be done by the AI. Now, of course, you need you need a compliance office at the end to check it, but um saving that time. And I think for scalability perspective, it can be a huge um yeah, a huge benefit.

SPEAKER_00 24:23

Does that affect many jobs do you think uh at the entry land or the progression end? Can it take away many jobs? I know the compliance is still going to be needing to check it, but do you think maybe from an early stage?

SPEAKER_01 24:34

Potentially. It I won't say taking away jobs. I think we're more looking at efficiencies and scalabilities. I think a lot of times, particularly in the fintech space, we're running very, very lean models as is. It just will help us to be able to scale with those continuously having lean leaner models. Um because I don't think adding more people is always the solution as well. Um, it can be use of technology, use of AI, it it makes a lot of sense. But ultimately, regulators will still expect compliance people to be in debt, yeah. Because yeah, we need to make sure that what we're submitting to regulators, but also submitting to FIUs is quality, that they're not just getting as well. That you know it, yeah. And that and that if you're submitting a SAR to the FIU, to the NCA, you need to ensure that that is useful. I mean, there's nothing I'm sure that's more frustrating in the NCA than getting useless SAR. So I think it is super important that we continue to have compliance officers. So I'm not getting rid of them yes.

SPEAKER_00 25:34

But utilize it. Utilize the technology. Do you think?

SPEAKER_01 25:40

Oh, uh I don't think so just yet. Um, I think that we've got a lot of space to go. Um, but yeah, getting ready, like like with with everyone, like with everywhere right now.

SPEAKER_00 25:52

And obviously, you're in a pretty senior role. What's the what's the challenges of running you know a big function that you're currently in at the moment? Is uh anything that springs to mind?

SPEAKER_01 26:01

Um well I think it's for me, right, it's a lot of different jurisdictions. Um so at the moment, like I mentioned earlier, we've different licenses and different jurisdictions. We also have different MLROs and different different jurisdictions. Um, so it's around getting a cohesive uh framework and being able to ensure that we're working together to come to really the goal of protecting the firm overall. So because I've got people in Austria and Germany and UAE in the UK, um, it is around just that challenge. Are we all working together? Are we working to the same hymn sheet, etc.? Um, yeah, but you know, it works, it's fun. We do a lot of outsourcing back to the Austrian entity, which makes sense because that's where our biggest uh office is, that's where most of our people are. Um, and um, and that does help because it is just ensuring that um there's consistency in in the processes that that are being run.

SPEAKER_00 26:54

Is your passport full of stamps then with all the traveling?

SPEAKER_01 26:56

Well, I I have an EU passport and remind you I'm an Irish accent uh if you can't tell already. So no stamps, which is really frustrating. I'd love a few more stamps.

SPEAKER_00 27:05

Because you must be in Vienna a bit.

SPEAKER_01 27:06

I'm in Vienna quite a bit, yes.

SPEAKER_00 27:08

Normally sort of, how often would you say?

SPEAKER_01 27:10

Um well, usually around once a month or so, and then sometimes more frequently. We've done a bit of travel. We've got also an office in Barcelona, we also have an office in Berlin. So I get to travel to the fun places. Yes.

SPEAKER_00 27:22

And what about budget restraints? Do they impact financial crime? Are you seeing much in that?

SPEAKER_01 27:27

They they do impact. I mean, budget restraints impact everyone in a business. Um, certainly, obviously, in in more challenging markets, budget restraints are consideration. Uh, they they impact every aspect of it, including financial crime, including compliance. I think it's important just the firms are making sure that they are doing the right thing. It might mean that some of the nice to have's are the things that that that are the least priority on someone's list. Um, potentially you don't get to go to a conference you'd like to go to. But you know, it it's at the forefront. Compliance is always up at the top of mind. Yes.

SPEAKER_00 27:59

What about the the new younger generation coming through? Do you think they're gonna have to adapt to anything? Maybe that you guys didn't they're gonna have to learn new things and be more up to date with AI, do you think, coming through?

SPEAKER_01 28:08

It's definitely more use of technology. I like you know, I can almost compare myself to my old days uh of kind of going through customer files, going through Naster Diligence files, doing a lot of writing. There'd be less writing.

SPEAKER_00 28:22

Uh but that would have helped you a lot, obviously learn and getting into the details.

SPEAKER_01 28:26

So I think there'd be a gap there where they're relying on Yeah, I know I sound old now saying it, but um yeah, I do think I think writing is a really valuable skill and you learn a lot by doing it. And by but this is a general issue. I don't think this is just unique to compliance or unique to our industry. I think this is just making sure that people continue to read and write and not fully rely on AI, but it's it's a shortcut. It's it's and it's a great shortcut where it can be.

SPEAKER_00 28:54

Is there a hardest internal trade-off you're seeing? Is that like risk, speed? What are you seeing at the moment, Dave?

SPEAKER_01 29:00

Um I think speed is a definitely consideration. Um, certainly in crypto and in fintech, there is emphasis on speed, it's there's emphasis on getting products out of the market as soon as possible and making sure that we're keeping up with competitors. Um and sometimes there is a trade-off to a certain extent. I would say that from my perspective, the important thing is to always have a practical and risk-based approach, which of course we're allowed to have from a regulatory perspective. Um, and you know, actually assess that risk and be able to look at our risk acceptance uh and risk appetite statements and say, is it within our KRIs, is it uh outside of tolerance, etc. That's where potentially the trickier conversations happen. But I think that's why it is still important to have compliance officers who can exercise discretion and know what is potentially pushing things too far versus what is acceptable for something.

SPEAKER_00 29:52

I'd say so. I think uh don't think the robot can do that.

SPEAKER_01 29:55

No, not yet. Yeah, not yet.

SPEAKER_00 29:56

What about policy papers? I'm sure there's loads of good stuff in them, but sometimes things fall down. Is there stuff that you've seen that maybe falls down?

SPEAKER_01 30:04

There's a lot of really good consultation papers out there at the moment. I think the challenge um is potentially there's not a not always the same amount of engagement prior to publishing of a consultation paper. So sometimes there is a lot of commentary coming back from industry after that, although I do think there's a lot of effort being made, like I said earlier, to actually engage with the firms and giving a huge amount of opportunity to provide feedback. I think it is around um can we ensure that that feedback is taken on? Of course, that that that's something that is is a consideration for all firms, but uh there's there's good stuff out there, yes.

SPEAKER_00 30:40

I'm sure there is. Are you seeing crypto compliance more of a competitive edge now these days, more than like a cost centre? Would you say that would be fair?

SPEAKER_01 30:48

Um I think it's still viewed as a cost centre by some. Uh, I think personally it's a competitive edge. And I think our our firms also say that. I certainly think BitPanda recognises the value and the importance of being heavily, not heavily, but at least a regulated firm. Uh personally, I think definitely think it will become more of a competitive edge because, you know, as as we see, more trust will be in regulated firms and the regulated industry. Um, and that that is going to help. I think internally, of course, it's still considered a cost, but that's not unique to compliance to crypto. I think that's you know, generic in all cases. Um, because of course it's not a revenue generating function, so there's always going to be a cost associated, and it's important that we work with the business. I think, though, it's to explain right the cost of non-compliance is much higher. Yeah, definitely. Yeah, exactly.

SPEAKER_00 31:41

What about crypto compliance? It's obviously it's definitely evolving. I mean, the last two years, I think it's really gone boom. Where do you see it in sort of five years' time?

SPEAKER_01 31:48

Oh, well, I'm hoping that there will be a system for travel rule where there's consistency from a global perspective. I heard some rumors that Swift were going to try to do what they've done for Fiat for travel rule. I don't know how accurate that is. Um, and I that would be really fantastic because I just think if there was consistency and there was not necessarily the same sunrise issues, we would be in a much better position as an industry overall. I think also the more sort of Mika equivalent regulations that come in, the better the industry is, yeah, for fair and consistency. So there's not this opportunity for regulatory arbitrage, right?

SPEAKER_00 32:25

Okay. Do you think that anything anything is going to be outdated within the industry in the next three to five years?

SPEAKER_01 32:30

In crypto, yeah. Um in the industry, possibly. In compliance, probably not, actually, because I think we're really still developing. Um, maybe the way that we do things will be outdated, and like we say, we want to continue to develop. Uh, we're looking at new AML regulation, for example. Um, so it just means some of the older stuff does become outdated. That's the nature of the beast. Um, sadly, it's usually not necessarily that it goes, but it's built on top of the case is is uh is unfortunately the case in in our industry. Um, so it just means not necessarily decommissioning something, but just making them bigger and more opportunities.

SPEAKER_00 33:07

Are there any underestimated financial crime risks within crypto, you think?

SPEAKER_01 33:11

Underestimated? Oh, um I I don't know if they're underestimated. I think there are some that maybe are not viewed uh in the same way as others. Um I thought, yeah, I'm trying to think. Underestimated, no. Um, one thing that I find super interesting and isn't necessarily so a lot of, for example, a lot of there's a lot of talk for sends to dark net markets, illicit activity in that way. Um, but I think sanctions compliance is one of the areas that we still need to look at. I don't think it's underestimated though, but but it's an area that needs more focus. Okay.

SPEAKER_00 33:49

When things go wrong in terms of like the blame, is that kind of on you guys? Is that fairly shared with regulators? How does it typically work? Be interesting to get your view.

SPEAKER_01 33:58

Um when things go wrong, you mean from from uh a business perspective or um well uh there it depends on what has gone wrong and ultimately it whether there there is something at fault, right? I mean, ultimately if it's a control failure, well that then that that is on the firm. Um but I think a lot of the time when things go wrong, it's around how you handle it is the key. Um if, for example, hypothetically something went wrong, it's around do you need to notify the regulator, at what stage you need to notify the regulator, what exactly needs to go. And then that becomes more challenging because you don't want to have a discussion with the regulator when you don't have data and you're not quite sure what has happened. So, for example, if there's a large hack, um and of course there are requirements around Dora, incident reporting, etc., um, that it then it's conversation internally. Um but of course, certain requirements have to be case by case, really. Exactly. Yes.

SPEAKER_00 34:52

Okay. If you could change anything, a regulatory change, what would it, what would that be?

SPEAKER_01 34:57

If I could change anything, right? But a magic wand, you could do it today. Um I would probably change the rules around travel rule and self-hosted wallets because they're really difficult to adhere to. Um and yeah, I I just feel like the regulators, the intention there is really good. Um, it makes sense, but the technology is not there to support it. So it becomes something that's almost impossible to adhere to properly. And that's very difficult for a compliance officer.

SPEAKER_00 35:25

What keeps you excited? I guess financial crime is it's it's not niche, I guess, but obviously to to people who don't know compliance and financial crime, friends, you know, what keeps you in this space and excited?

SPEAKER_01 35:36

Some people like really think it's cool, you know, and you're like, oh like a detective. Yeah, exactly. Well, I I it's sad that I don't get to do as much of the hands-on work as I used to when I was younger. But like I think what's super interesting is like actual investigations. And I sat down with a team member of mine not that long ago, whereby he was showing me, bringing me through to analysis, um, like multiple hops behind, you know, in the chain, looking at all these different threads, and I just thought, that's really cool. That's really interesting. I wish I could show everyone that. I wish we could all sit down and go, here's how we really detected this potential dissed activity. Um, and that's what keeps me excited because I think that emerging technology is really quite amazing and it looks really cool. So yeah. Okay, cool.

SPEAKER_00 36:21

How do you stay current then? Do you is there anything you do to stay current, or are you just into the detail daily that you evolve?

SPEAKER_01 36:27

Uh staying current is I think a mixture of like horizon scanning from a regulatory perspective, trying to go to seminars, trying to go to the law firms do amazing seminars, as you probably know. Also, the FCA does amazing seminars. But there's so much out there, it's almost impossible to keep it. So overwhelmed a little bit. It is a little bit, yes. I definitely so yeah, use of AI. Shh, don't tell anyone. Back to AI. To a certain extent, yeah, is really useful, right? Summarize the key regulatory publications in you know, X, you know, having the right prompts and then learning that as a tool is in itself, right? But you do it through trial and error. Um, I think seminars, talking to peers, I do a lot of talking to peers. Uh, I have certainly done a lot of talking to peers um in in other firms in the last couple of years about things like travel rule, where we're kind of all facing the same issues. So staying friends with your compliance colleagues in other areas is always good.

SPEAKER_00 37:19

Definitely. It's a small space. Um the market's booming. There's there seems to be lots of hiring. What do you look for when you're hiring in BitPanda? Is there anything you're specifically looking for? And you've how are you finding getting good talent?

SPEAKER_01 37:31

Yes, uh, that's really interesting, I think, because BitPanda, as many other fintechs, has a set of principles that it looks at for DNA principles. So that's a key thing. When we look at hiring in BitPanda, we look at, of course, the job spec and the role, we do a recruiter screen, then we do a technical interview usually, but we always finish with what we call a bar raiser. Okay. So we want to make sure that whoever joins us meets the DNA principles, and then we actually have bar raiser questions. And the bar raiser, I think what what's really interesting about it is it's not necessarily someone who's in your department.

SPEAKER_02 38:05

Okay.

SPEAKER_01 38:05

So we can often have somebody who's completely outside of the department do the bar raiser, and that really means that it's principles focused rather than technical. And I like that about that because now I tell I have done bar raises for people in finance, I have done bar raises for people in engineering.

SPEAKER_00 38:21

Takes the emotion away a little bit from them having that skill set, and obviously more generically what we're looking for from a culture point of view.

SPEAKER_01 38:27

Exactly, and a culture is a culture is a big thing. When we look at um, a how we recruit, but also how we reward, we look at uh obviously technical skills and how someone's done their job well, but we also look at culture, are they culture fit? Um, because that's really important to the organization.

SPEAKER_00 38:42

What do you think about people coming from different areas? So obviously I know some people like have to have crypto. Are you open to like all payments? Would you take people from consultancies, banking? What's your view?

SPEAKER_01 38:51

I really am, I definitely am. Um it depends on the role, of course. I have we have potentially some roles in let's say crypto and blockchain monitoring specifically. So it's more difficult to say, you know, yeah, we we won't have any experience. But arguably, you know, crypto's still a relatively new industry um in terms of financial crimes. So it is very difficult to say we want an absolute expert in all of these areas. I think personally it's having an open mind is huge. Um, yes, of course, having somebody who knows what they're doing is is is absolutely paramount. But for me personally, when I'm hiring, I look at whether somebody is smart and nice, right? Because, you know, you want somebody who you can get on with, who can get on with a team. Like I say, having that empathy, being able to have conversations with other teams, know where they're coming from, be able to explain the why. And smart people can learn anything. I'm convinced of it.

SPEAKER_00 39:46

I'd say so. Yes. Is there anyone that you've kind of looked up to that you've learned off throughout your career, like a an old boss or someone that maybe took you on a journey when you were up and coming?

SPEAKER_01 39:55

Definitely. I've got a few uh former bosses. Um I I should I name drop them? I I don't know. I can. Anyone that's um so one one that stands to mind. Well, well, a couple stand to mind. One is um a fantastic woman called Sue Gannon, who uh she previously worked with me in the firm in Dublin, Jamie Davy, and then hired me at Morgan Stanley. Wow. Um so first of all, that goes to show obviously having connections in the industry, but also just keeping those relationships alive is super important. Um, and you know, Sue was great inspiration to me. She went on and become the head of Global Head of Financial Crime at uh Nordeea Bank. I think she's recently moved back to London, actually. Um, but really just uh inspiring, definitely an inspiring person, having worked her way up through the ranks. Um and um another person who comes to mind is my former boss at Coinbase, uh G Tampitel, um, who, yeah, just really great person to work with, very practical, really enjoyed bouncing ideas off them. So yeah, it's fantastic to work with people. And I I I love the industry in that really compliance is a close-knit circle. A lot of people know each other, we move around a lot, we often meet at drinks related to you know, folks like yourself. Um, and uh I, you know, also uh yeah, Satan Am Lee Hall as well, who I worked with as Morgan Stanley. Um yeah, huge, huge amount of people, huge respect for the people.

SPEAKER_00 41:19

Definitely some people who've impacted you then. I'm sure you're doing the same uh to your team, Z.

SPEAKER_01 41:23

Oh, I hope so, but I don't know. I can't promise it.

SPEAKER_00 41:26

If you weren't uh doing what you're doing, if you weren't in financial crime compliance, what would what do you think you'd be doing?

SPEAKER_01 41:30

What would I be doing? Um I don't know. Uh I I think uh I I've always been really interested, and one of the things I was super interested in is like public policy and and like I'd love to work for like a supranational, like you know, the UN or something like that. That that would be incredibly cool. Um a difficult job, but actually I had really exposure to uh the UN counterterrorist team when I went at a conference uh speaking as a panelist in in Sarajevo a few years ago. So that was really, really interesting, and I see the work they do, and it's amazing. Okay.

SPEAKER_00 42:05

One last question before we do some quick fire rounds. Is there anything um that's an uncomfortable truth in crypto that people don't typically say? Anything you you could think of?

SPEAKER_01 42:14

Uncomfortable truth in crypto. I think um I think there's still a lot of myths around the anonymity factor and uh the untraceability. And I just think that's not true and uh is something that was a sort of a myth we need to debunk. Um but yeah, it's it's it's a challenging industry and it's still a growing industry. We need to all work together to make it a success. And from a regulatory perspective, I think we're doing that.

SPEAKER_00 42:41

Good, awesome. Okay, bit of fun now. Um morning routine, is it well planned? Are you getting up at 5 a.m. or you you're having a nice bath and a and uh an espresso, or are you chaotic?

SPEAKER_01 42:53

Um organized chaos is really what I'd say. Yeah, I I have I have a routine, I rarely stick to it. I often have early calls because I'm on um, you know, I've got a team in UE and um Oh, early silly. Yeah. Not not no, not super early. Yeah. I mean, I usually start at eight, but it's not super early. Yeah.

SPEAKER_00 43:11

Yeah. Guilty Pleasure TV show. Have you got anything?

SPEAKER_01 43:14

I've loads of TV shows that I love. Yes, or podcasts indeed. Yeah, probably shouldn't say the podcast because I'd be risk unprofessional. An Irish one that many of you might know. Um, what I've really enjoyed recently was Pluribus on Apple TV. I don't know if you've seen it. No. It's weird, but it was cool. Yeah, I I I had only heard of it a long time after it was already out, and then all of a sudden it was winning golden globes and Emmys and yeah, all of the stuff. It's it's it's weird.

SPEAKER_00 43:44

Yeah, it's traitors for me. I've been a good one. Oh, I love trade traitors. Okay. Yeah, unbelievable.

SPEAKER_01 43:48

Oh, I love traitors, amazing. Yeah, definitely.

SPEAKER_00 43:50

Did you see um there's a there's a program, I'm not sure what it's called. It's about laughing, all the comedians.

SPEAKER_01 43:54

Oh, last one laughing. Last one we watched that. I did. Have you seen that? Yeah, yeah, super fun.

SPEAKER_00 43:59

And they literally they can't look at each other because obviously they're asking some really funny questions.

SPEAKER_01 44:02

I tried to do it then with my husband and I immediately lost. It lasted about three seconds. Yeah, I couldn't do it. Yeah, good.

SPEAKER_00 44:09

Well, that's all the questions. Really uh appreciate you coming on today. Thank you. Thought you did some uh amazing answers, and yeah, loved having you on. So thanks, D.

SPEAKER_01 44:15

Thank you so much. Thanks for having me on.

SPEAKER_00 44:16

Cheers, thank you.