Financial Crime Professional
Compliance and forensic professional with over 20 years of proven experience track in preventing, detecting and investigating financial crime, primarily in the financial services industry. Having worked both for commercial and advisory entities, his expertise covers the whole fraud risk management cycle, from setting up relevant control frameworks, operating and refining processes and tools up to reviewing their compliance and effectiveness.
Mikolaj specializes in managing financial crime in the fintech industry, recognizing the power of automated controls and machine-learning business logic in fighting cybercrime. He run numerous complex engagements involving risk assessment, corporate fraud deterrence, anti-money laundering programs, internal investigations and digital forensics. He holds several professional designations in the areas of fraud risk management, computer forensics, anti-money laundering and auditing.
He is the frequent speaker and trainer on domestic and international events devoted to financial fraud, anti-money laundering and digital forensics. He authors Fraud IQ: a web portal aimed to spread fraud awareness by sharing useful risk management stories among business professionals.
Hitachi Vantara is the global leader in operational technology, providing high- and mid-end data storage infrastructure, applications, analytics, content, cloud, and related services.
The Global Compliance provides assurance on Hitachi Vantara’s compliance with regulatory requirements, internal procedures, industry best practices, and principles of business conduct. We make sure the way we do business does not endanger business continuity, jeopardize financial standing, expose to legal actions or compromise our reputation.Principal responsibilities include:
- enforcing compliance & risk management framework throughout the business processes in the region,
- performing compliance risk assessments and recommending necessary internal control improvements,
- executing complete analysis of accounting, finance, economic issues in the context of business transactions and initiatives/projects of different nature,
- providing guidance and advisory to management on preferable procedure and conduct,
- operating anti-corruption controls, following FCPA, UKBA and local regimes,
- developing and supervising the company’s anti-money laundering controls,
- supervising and conducting forensic investigations addressing violations of the Code of Ethics & Business Conduct,
- co-running and supporting other special investigations (information security, data privacy, employee relations),
- conducting special reviews of processes/areas of high compliance risk,
- providing training and enforcing compliance awareness among employees, contractors and partners,
- supporting third-party due diligence process.
International Personal Finance is a leading provider of home credit and digital loans, serving over 2.2 million customers across 11 international markets, under several first-choice brands like Provident, Creditea and Credit24.
Financial Crime Decision Systems is the only cross-business entity within IPF, covering both home credit and digital lending divisions. It is responsible for maintaining and developing automated anti-fraud and anti-money laundering engines, tools and solutions helping the business protect itself from different manifestations of financial crime.
This excellence center is primarily entrusted with:
- developing, together with the respective stakeholders, the IPF’s strategy for fraud and money laundering prevention and detection,
- selecting, evaluating and testing automated anti-fraud and anti-money laundering solutions of potential interest,
- providing expert advice on cost-effective automated controls throughout the business and for future initiatives,
- drafting technical specifications and working with IT on integrating the respective systems into IPF’s IT framework,
- administering systems in place and enforcing systems governance principles,
- acting as the contact point for vendors and as the 1st line technical support for internal users,
- designing, implementing and advancing the automated financial crime controls in place, aligned with the markets’ risk appetite,
- evaluating effectiveness of current systems logic in place and constantly improving / extending it,
- investigating suspected and actual cases of fraud and information security,
- automating existing manual and semi-automated processes in the financial crime area,
- tracking and reporting system usage, trends, KPIs, exclusions and deviations.
IPF Digital is the online lending division of International Personal Finance Group, well-known for its home credit brand, Provident. It provides credit lines and installment loans under Credit24, HapiLoans, Creditea and Sving brands, currently on the eight markets worldwide: Spain, Poland, Finland, Estonia, Latvia, Lithuania, Mexico and Australia.
I am heading the Financial Crime Team responsible for securing the business from external and internal fraud losses, money laundering incidents and information security breaches.
My daily duties comprise of:
developing and enforcing the loss prevention framework across digital business,
designing market-specific technical and operational controls preventing internal and external frauds,
developing customer fraud and money laundering risk assessment principles and resulting due diligence practices,
administering and developing tools and systems providing online fraud and money laundering protection,
examination of internal and external fraud suspicions, attempts and actual cases,
enforcing information security principles within IPF Digital internal data environment,
monitoring national legal environments and assuring compliance with relevant requirements,
cooperation with law enforcement representatives,
researching financial crime regulatory requirements, tools availability and risk management practices while rolling out IPF Digital business over new markets,
developing and implementing adequate anti-fraud, AML and information security frameworks while setting up businesses in consecutive markets.
fraudit was the independent advisory practice, specialized in fraud risk management solutions, corporate investigations and anti-money laundering services. It was founded as the professional alternative for companies seeking forensic services and fraud advisory on the market predominated by big consulting firms. It offered a comprehensive range of services supporting companies in fighting and investigating fraud and malpractice.
The services rendered included the following:
performing corporate investigations, both independently and in co-operation with internal taskforces,
conducting quality reviews of anti-fraud and anti-money laundering frameworks,
providing computer forensics and e-discovery services (evidence acqusition, processing, analysing and reporting),
performing processes and products fraud and money laundering vulnerability reviews,
designing and optimizing anti-fraud and anti-money laundering programs, processes and procedures,
delivering business intelligence information on agreed matters,
building fraud awareness by delivering internal training and designing relevant materials.
EY’s Fraud Investigation and Dispute Services is the advisory practice providing assistance to companies facing fraud, government investigations, regulatory inquiries, major litigation or transactional disputes. It delivers combined expertise of forensic accountants and technologists, certified fraud examiners, anti-corruption and anti-money laundering specialists.
I was primarily responsible for attracting and servicing customers from the financial services industry, however I also headed several assignments provided to other industries, whenever financial transactions were in scope.
My core responsibilities included:
- developing and marketing products and services aimed at financial industry,
- preparing sales offers and negotiate projects’ budgets, scope and deliverables,
- managing projects related to investigating fraud, corruption and money laundering incidents,
- advising on fraud and money laundering risk management frameworks implementation and refinement,
- recommending fraud-related internal controls aimed at reducing fraud vulnerability, error proneness and lowered effectiveness,
- performing forensic due diligence of the planned mergers and acquisitions’ targets,
- monitoring industry best practices and benchmarks in order to keep customers in line with the latest solutions,
- supporting EY’s “though leadership” initiative by publishing articles, giving speeches and presentations, drawing up survey studies.
ACFE Polska is the local Chapter (#114) of the Association of Certified Fraud Examiners, the world’s largest anti-fraud organization and provider of anti-fraud education. Its mission is reducing the incidence of fraud and white-collar crime and to assist its members in fraud detection and deterrence.
I was appointed as the President of the Board by the Annual General Members’ Assembly and entrusted with managing the Chapter’s activity on the Polish market.
My core responsibilities included:
- promotion of the anti-fraud profession to the local business,
- cooperation with ACFE Headquarters and peer European chapters in spreading the fraud awareness and facilitating knowledge sharing,
- organizing and participating in the industry events devoted to financial crime and risk management,
- cooperation with local entities involved into economic crime prevention (Police, Prosecutor’s Office, Central Anti-Corruption Bureau, Ministry of Internal Affairs, Association of Polish Banks),
- administering the Chapter’s everyday activity,
- running ACFE Polska’s website, discussion forum and social profiles.
BNP Paribas Fortis was the brand used by the Fortis Group after having been globally taken over of by the BNP Paribas Group. Its Polish subsidiary was a middle-size universal banking institution serving corporate, retail and consumer finance customers. Currently, after acquisition of another Polish bank, it operates as BNP Paribas Bank.
I was entrusted with establishing and leading the in-house forensic practice supporting the bank with prevention, detection and investigation of any financial crime instance.
My core responsibilities included:
- designing and implementing strategy and methodology of fraud risk management and cases examination,
- leading and coordinating fraud risk assessments, designing and testing fraud-related controls,
- advisory for the Board and senior management on effective fraud risk management and internal controls,
- performing vulnerability analyses of agreed products, processes and IT systems,
- training employees on preventing and detecting internal and external fraud,
- maintaining the internal Fraud Alert System,
- conducing fraud investigations in cases of internal and external frauds and money laundering situations,
- daily cooperation with peer financial companies in financial crime information exchange and best practices sharing,
- reporting incidents and facilitating legal proceedings towards suspects and perpetrators.
Group Investigations was the BNP Paribas Fortis global assurance function focused on fighting financial crime across all Group core business lines (banking, leasing, securities, insurance, investment management, factoring). It was disbanded as a part of organizational changes following acquisition of Fortis Group by BNP Paribas Group.
I was entrusted with establishing and leading the country-level network of risk specialists collectively protecting Group’s Polish businesses from fraud and malpractice. At that time Group’s local business was run through 8 specialized entities.
My core responsibilities included:
participating in designing the Group anti-fraud strategy and operational procedures,
managing fraud risk on the country level via planning and executing necessary actions and compiling management information,
enforcing and verifying local implementation of the relevant policies within Polish business units,
advising, consulting and supporting the particular risk officers located in different business lines,
coordination of preventive and detective measures taken by the particular risk officers,
conducting fraud examinations in case of fraud suspicions,
sharing best practices, case studies, early warnings and expertise within Group Investigations members.
Trainings & Conferences
Designed and conducted numerous (20+) original subject matter trainings and workshops, lasting from 1 up to 5 days. They were delivered to the closed internal groups as well as available to the general public and highly appraised by the participants.
Example topics covered included:
- assessing fraud risk and building the fraud response plan,
- conducting internal investigations,
- utilizing computer forensics in corporate investigations,
- preventing and detecting credit application frauds,
- establishing comprehensive fraud risk management framework at a company,
- establishing effective anti-money laundering programs,
- designing Know Your Customer programs and applying customer due diligence.
Prepared and delivered numerous (40+) audience-adapted presentations and lectures on domestic and international events (locations included i.a. London, Amsterdam, Berlin, Prague and Warsaw). The conferences attended combined both those devoted exclusively to financial crime area and to more general risk management and compliance matters.
Example topics covered included:
- incorporating financial crime risks into corporate risk assessments,
- internal auditors’ responsibility for fraud prevention and detection,
- strengths and weaknesses of device profiling in application fraud detection,
- use of computer forensics in fraud prevention,
- detecting malpractice in automated environments,
- e-banking fraud – recent threats and their early prevention,
- from interview to interrogation – the art of acquiring information,
- encouraging employees to blow the whistle,
- establishing money laundering risk scoring models,
- auditing forensic function in an organization,
- compliance, operational risk and anti-fraud functions – getting together,
- particular anonymized cases studies and lessons learned from them.
Core competency areas
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