Compliance professionals face an increasingly complex task, writes Natasha Baluchi, who attended this year’s JCOA conference
FINANCIAL crime is becoming increasingly complex, with investigators often needing to look beyond individual transactions to uncover the networks and relationships behind them.
That was a central theme of this year’s Jersey Compliance Officers Association conference, held at the Radisson Blu Waterfront Hotel on 28 September.
Hosted by JCOA chair Nicola Ingram, the event brought together investigators, journalists and policymakers to discuss cryptocurrency, corporate structures, financial regulation and whistleblowing.
Opening the conference, Senator Elaine Millar spoke about Jersey’s international financial services reputation and the importance of maintaining effective regulation while ensuring the Island remained an attractive place to do business.
She outlined work to make processes more efficient, including improvements to customer onboarding and a more proportionate, risk-based approach to regulation.
“The privilege has shifted. It’s no longer a privilege for financial services businesses to operate in Jersey. It’s a privilege for Jersey to serve them,” she told delegates.
Her remarks set the scene for presentations exploring how compliance professionals can identify risks, connect information and recognise when something does not add up.
Among the speakers was Alexander Browder, a 17-year-old cryptocurrency investigator whose work focuses on tracing money laundering and documenting illicit activity.
“I’m the youngest person ever to be sanctioned by Russia,” he told delegates.
The son of anti-corruption campaigner Bill Browder, Alexander created the Global Cryptocurrency Laundering Database, an open-source resource documenting cases involving cryptocurrency. His report for the Henry Jackson Society examined 164 cases spanning 20 years and estimated that around $350bn had been laundered through cryptocurrency across those cases.
“I’m 17 years old. I was still in high school. I come from a long line of people who focus on anti-corruption, and my father’s a big human rights activist who has always inspired me. I felt I needed to do something,” he said.
“Cryptocurrency is a space not many people understand, and so I think being young gives you an advantage in this.”
Alexander described investigating A7A5, a rouble-pegged stablecoin used to move money through a network linked to Russia despite international sanctions.
His work involved examining exchanges and other services supporting the stablecoin, including those operating in Kyrgyzstan. He explained how identifying the organisations enabling a network to function was an important part of tracing financial activity.
Getting authorities to act presented a different challenge, particularly when organisations operated across borders.
“How do you get someone, a foreign country, to take down this massive scheme when you have no power or authority there?” he asked the audience.
Alexander worked with politicians across party lines, helping organise 26 MPs to write to the UK foreign secretary and call for sanctions against those enabling the operation.
His investigation formed part of wider efforts to disrupt the network. Blockchain analytics company Elliptic subsequently reported that A7A5 transaction volumes had fallen by 96% from their July 2025 peak. The decline, however, should not be attributed to Alexander’s intervention alone.
The conference also heard from Ray Blake and Graham Barrow, who have worked together for around 30 years investigating financial crime and mapping connections between companies and individuals.
Their work uses publicly available information to identify relationships that might otherwise go unnoticed.
“We felt passionately that there was a role for a firm to take as much public data as they could, and start mapping it, because that gives us the ability to provide others with an important picture of what’s going on that otherwise they wouldn’t have seen,” Mr Barrow said.
Their presentation included an investigation into a corner shop in Hull, which led them to examine around 120 companies connected to the address. By mapping company records and relationships, they demonstrated how apparently disconnected information could reveal a wider network.
The pair also questioned whether identity verification alone could provide a meaningful assessment of risk.
“People are putting a lot of faith in the fact that directors and officers of companies now have to have their identity verified,” Mr Blake said. “But, as anyone who’s worked in a bank for the last 20 years knows, just verifying somebody’s identity doesn’t tell you a great deal. Because criminals have identities too.”
Their message was that checking whether the necessary information was present was only one part of the process. Compliance professionals must also consider what that information reveals and whether it fits the wider picture.
Franz Wild, chief executive and editor-in-chief of the Bureau of Investigative Journalism, explored a similar principle through the organisation’s work examining corporate structures and financial records.
He discussed an investigation into Russian billionaire Roman Abramovich’s business interests, using material from Cyprus Confidential, a leak of more than 3.6 million files from six Cyprus-based financial services providers and a Latvian company selling Cypriot corporate registry documents.
“We decided as a bureau to focus on Roman Abramovich, and we started cataloguing all the companies he had. This is basically a 20-year anatomy of Roman Abramovich’s corporate empire,” Mr Wild said, referring to material shown during his presentation.
The investigation illustrated how examining records across companies and jurisdictions can help journalists piece together complex business relationships.
Mr Wild highlighted the importance of understanding the story behind financial documentation, rather than simply checking whether the correct paperwork had been present.
“It’s not just about, ‘Have we got all the right documentation?’ It’s: are we happy that the story it’s telling us is consistent with what we might know from other sources?” he said.
The conference also included a discussion on whistleblowing, with speakers considering how information from people with direct knowledge of suspected wrongdoing could support investigations and why those who come forward need protection.
Across the presentations, the emphasis was on connecting information, questioning assumptions and looking beyond individual transactions or documents.
For compliance professionals, the challenge is not simply to establish that the necessary checks have been completed, but to understand the relationships and risks those checks may reveal.
As the speakers demonstrated, that work can involve international financial networks, detailed corporate research or the careful examination of public records. In each case, the starting point is the same: looking beyond the information immediately in front of you to understand the bigger picture.
