Tom Fox’s guest on this week’s show is Dan Wager, VP of Global Financial Crime and Compliance at LexisNexis Risk Solutions. Dan is an executive with expertise in financial crime compliance and investigations. He and Tom discuss human trafficking, fraud and identifying the patterns of suspicious behaviors within an organization. Tom emphasizes, “All compliance professionals need to understand not only the risks around this area but also what the solutions are… The pandemic has caused an increase in this area because it’s closed down other business opportunities for the bad guys.”



It’s All About Money

Human trafficking, sex trafficking, money laundering and the like are not crimes of passion, Dan points out. “Their focus is to make money and that desire does not stop during an economic crisis and a global pandemic… It all comes back to moving money.” The way in which these crimes are committed is changing, and compliance professionals need to be aware. Tom comments that commercial corporations are being targeted more now because “they’re not set up to fight this scourge.” Dan explains why this is so and gives an example of how banks have been inadvertently used in PPP fraud recently. “These things move together – disadvantaged businesses looking for funds and illicit financiers looking for outlets, people on the narcotics or human smuggling realms looking for ways to make money and retain money in a difficult environment – they all fit together.”

Reputational Risks

Tom comments that your company’s reputation will be severely tarnished if you are found to be even remotely involved in human trafficking and human slavery. Dan says that most companies understand this but are struggling to detect it. You don’t want to be a company that purchased PPE from non-vetted suppliers because you’ll go down along with them, he warns. The reputational damage is just one part of the equation. “What do you think happens to those kinds of workers when you have counterfeit and hard-to-get PPE, in this kind of environment where they can’t even travel across the border or seek other employment? It is exploitation and health dangers on an epic scale,” Dan remarks.

Working From Home & Red Flags

Tom and Dan discuss the increased risk because of the move to work-from-home. Tom also asks about the risk that returning to work may bring. The speed with which remote work had to be implemented opened up new avenues for fraud, Dan says. Work computers are now sitting alongside personal network computers, and bad actors are using various ways to infiltrate both. Few companies are equipped to deal with these changed circumstances, which leaves them vulnerable. The way we conduct business has changed permanently, Dan remarks. This is good in many respects, but it opens up opportunities for fraud. He shares some red flags compliance professionals and financial institutions should look out for. If there is a dramatic change in how a company usually does business, that’s a major red flag, Tom and Dan agree.


Dan Wager | LinkedIn

LexisNexis Risk Solutions