Integrity Insights

The Berlin Risk Podcast

Integrity Insights is a podcast from Berlin Risk, a Berlin-based corporate intelligence and compliance advisory firm. In the podcast, we cover the latest developments in the fields of financial crime, political risk, sanctions, open source investigations and much more. The podcast is hosted by Filip Brokes, consultant at Berlin Risk. 

  1. The Global State of Beneficial Ownership Transparency

    20. Mai

    The Global State of Beneficial Ownership Transparency

    In this episode of Integrity Insights, host Filip Brokes speaks with Thom Townsend, Executive Director of Open Ownership, about the evolving global landscape of beneficial ownership transparency. The conversation revisits one of the major turning points in the transparency agenda: the November 2022 Court of Justice of the European Union ruling, which restricted unrestricted public access to beneficial ownership registers. Thom explains how the decision created a “seismic shift” in Europe and beyond, prompting some jurisdictions to pause reforms or reassess public access models. At the same time, he highlights that the ruling also confirmed an important role for civil society, journalists and academia in fighting money laundering through access based on legitimate interest.  The discussion also looks at the United States, where the rollback of the Corporate Transparency Act has added further uncertainty to the global reform agenda. Thom reflects on what this could mean for FATF standards, mutual evaluations and the incentives facing countries that are still considering or implementing beneficial ownership reforms. A key theme of the episode is the difference between a register that merely exists and one that is genuinely useful. Thom explains why usability depends not only on whether data is accessible, but also on whether users can search by company and individual names, identify links across entities, access structured data, and rely on systems that support verification and cross-checking. He discusses examples from jurisdictions including Nigeria, Botswana, Austria, Denmark, Norway, South Africa and Argentina, showing that there is no single model for success. The episode also explores the practical challenge of verification. Thom distinguishes between verifying the identity of a natural person and verifying whether that person genuinely owns or controls a company. He explains why verification is a “team sport” requiring discrepancy reporting, cross-government data sharing, tax-data checks, land and property registers, and credible deterrence mechanisms. Despite political and legal headwinds, Thom remains broadly optimistic. He notes that around 150 to 160 jurisdictions have implemented, are implementing, or plan to implement beneficial ownership reforms, and argues that the global evidence base around beneficial ownership transparency is growing rapidly. Documents referenced:  1. The usable data framework - https://www.openownership.org/en/publications/usable-beneficial-ownership-data/  2. The Open Ownership map https://www.openownership.org/en/map/ charts progress globally. 3. Open Ownership's reaction to AML6 https://www.openownership.org/en/news/european-union-takes-important-steps-towards-standardised-and-interoperable-beneficial-ownership-information/ 4. Open Ownership's response to the 2022 CJEU verdict https://www.openownership.org/en/news/statement-on-court-of-justice-of-the-european-union-cjeu-judgement-on-public-beneficial-ownership-registers-in-the-eu/ 5. The launch of Open Ownership's new research project, BEAM https://www.openownership.org/en/blog/from-reform-to-results-introducing-beam-a-new-programme-to-measure-impact-in-beneficial-ownership-transparency/, which will work with researchers and academics to design more ways to measure the impact of BO information. Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    34 Min.
  2. The Value of Background Checks and Due Diligence

    20. Apr.

    The Value of Background Checks and Due Diligence

    In this episode of Integrity Insights, Filip Brokes is joined by Verena Horne (Director at Berlin Risk) and Davids Alksnis (Consultant at Berlin Risk) to discuss the fundamentals of background checks and due diligence investigations. The conversation provides a practical overview of how integrity due diligence works in real-world scenarios, why clients rely on external investigators, and how risks are identified, assessed, and communicated. Key themes discussed  Background checks vs. due diligence  The episode clarifies the distinction between the two terms: background checks as an initial screening process, and due diligence as a more in-depth, structured investigation aimed at fully assessing risks.  Why clients commission investigations  Clients typically seek due diligence when facing uncertainty around key decisions, such as investments, partnerships, market entry, or senior hires. The core objective is to understand who they are dealing with and what risks may arise.  Types of risks assessed  Investigations focus on a wide range of risks, including reputational concerns, source of wealth, sanctions exposure, governance issues, business track record, and behavioural red flags (including online conduct).  Methodology and approach  The discussion highlights the importance of a structured methodology based on the intelligence cycle: defining the research question, collecting relevant data, verifying sources, and producing actionable analysis rather than raw information.  OSINT and human source inquiries  While open-source research forms the foundation, many cases require human source inquiries to provide context, validate findings, and uncover information not available in public records.  Jurisdictional challenges  The availability and reliability of information vary significantly across jurisdictions. Differences in corporate transparency, media landscapes, and cultural norms can materially impact investigative approaches.  Case example: uncovering fraud  The episode includes an anonymised case where a seemingly credible company bidding for a major contract was ultimately revealed to be a fraudulent front for an individual with a history of criminal activity.  Working with limited or excessive information  Investigators must navigate both data overload and data scarcity. In low-information cases, creativity and alternative data sources become critical, while high-volume cases require careful filtering and prioritisation.  The impact of AI on due diligence  AI is increasingly used to process large volumes of information efficiently. However, the discussion emphasises the growing importance of verification, critical thinking, and human judgment, given issues around reliability, consistency, and trust. Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    32 Min.
  3. OSINT Techniques for Foreign-Language Research

    11. März

    OSINT Techniques for Foreign-Language Research

    In this episode of Integrity Insights, Filip is joined by Skip Schiphorst of i-Intelligence, a specialist in multilingual open-source intelligence and online research. Skip manages the company’s language-focused OSINT courses, including Chinese, Russian, and Arabic. The conversation explores a frequently overlooked aspect of OSINT: how to research effectively in foreign languages even if you do not speak them fluently. Skip explains why accurate searching in Arabic, Chinese, and Russian is about far more than translation, and why cultural, political and linguistic context remains essential despite the rise of AI tools. Key themes discussed Language-based OSINT as a specialist discipline  Skip explains how i-Intelligence trains analysts, journalists, and corporate investigators to search in foreign languages using the right methodology.Why translation alone is not enough  The discussion highlights the limits of Google Translate, AI tools, and literal transliteration when researching foreign companies, individuals, or media sources. Getting the exact local spelling or company name right is often the key to the entire investigation.Culture, politics, and context  Skip emphasizes that language research cannot be separated from local context. Understanding naming conventions, media ecosystems, religion, politics, and regional culture is often essential to interpreting sources correctly.Vetting foreign-language sources  The episode looks at the challenge of judging the reliability of local sources, especially in politically sensitive environments, and why building human networks and simply asking trusted local contacts can be as important as technical search skills.AI versus methodology  Skip reflects on how analysts increasingly turn to AI first, but argues that strong methodology still outperforms overreliance on large language models. In his view, AI can support research, but it cannot replace sound analytical thinking.Do you need to speak the language?  One of the central themes of the episode is that speaking a language and knowing how to research in it are not the same thing. Skip argues that non-native speakers with strong methodology can often outperform native speakers who lack OSINT training.Why learning languages still matters  The conversation closes on the enduring value of language learning, both for research and for human understanding more broadly, especially at a time of increasing geopolitical fragmentation and polarization.Links: Searching the Chinese Internet: Foundations Course https://i-intelligence.eu/courses/searching-the-chinese-internet-foundations OSINT: Searching the Russian Internet Course https://i-intelligence.eu/courses/osint-searching-the-russian-internet-virtual-course OSINT: Searching the Middle Eastern Internet Course https://i-intelligence.eu/courses/osint-searching-the-arabic-web Connect with Skip: LinkedIn: https://www.linkedin.com/in/skip-schiphorst-721bb6200/ Skip's Instagram page where he shares his language learning techniques  https://www.instagram.com/skipmovestolearn/ Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    29 Min.
  4. The Evolution of Open-Source Intelligence: A Conversation with Nico Dekens

    11. Feb.

    The Evolution of Open-Source Intelligence: A Conversation with Nico Dekens

    In this episode of Integrity Insights, we are joined by Nico Dekens, a recognized authority in the world of open-source intelligence (OSINT). With over 30 years of experience in the field, Nico shares his insights into the evolving OSINT landscape, the tools and techniques he uses, and the ethical considerations of this critical field. Nico spent over two decades with the Dutch police, working on intelligence and human operations, before transitioning to the private sector where he now leads engineering efforts at Shadow Dragon. We dive into how OSINT has changed over the years, with new technologies such as AI revolutionizing the process, but also the complexities of using these tools responsibly. Nico shares practical advice on how to start an OSINT investigation, how AI and machine learning are reshaping the future of intelligence, and how to stay up to date in a fast-evolving field. He also gives us a glimpse into his work on high-profile cases, where he uses his investigative skills to piece together puzzles from seemingly limited data. Key Takeaways: The Evolution of OSINT: Nico provides an overview of how OSINT has progressed over the past three decades, with a focus on the increased integration of AI and machine learning in the investigative process.Practical OSINT Techniques: Nico explains his approach to conducting investigations, from starting with a name or photo and using facial recognition tools to building actionable intelligence.The Ethics of OSINT: Nico discusses the ethical boundaries of OSINT, focusing on the use of publicly available data and the challenges of navigating the dark web and leaks without crossing legal or ethical lines.AI and OSINT: While AI tools provide huge advantages in terms of processing large data sets, Nico emphasizes that human judgment remains critical for interpreting and validating the data.Time Stamps: 00:00 – Intro & Background: Nico’s professional journey and his transition from the Dutch police to Shadow Dragon.04:20 – OSINT Techniques: How Nico begins an investigation and the tools he uses, including facial recognition software.10:00 – The Ethics of OSINT: Discussing the ethical challenges and limitations of OSINT, including using publicly available data.15:30 – The Role of AI in OSINT: How AI and machine learning are changing the field and the importance of human oversight.21:45 – The Future of OSINT: The rise of commercial OSINT, network-building in the community, and keeping up with the fast pace of technological change.Relevant Articles: The Slow Collapse of Critical Thinking in AI – Nico’s recent article exploring AI’s limitations in OSINT.OSINT is Still a Thinking Game – Discussing the balance between technology and human input in OSINT investigations.Listen to the Episode: Available on Spotify , Apple Podcasts , and Amazon Music Don't forget to follow Integrity Insights for more expert discussions on integrity, financial crime, and investigative techniques! Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    35 Min.
  5. AML in Transition: What 2025 Meant for Compliance in Europe

    26. Jan.

    AML in Transition: What 2025 Meant for Compliance in Europe

    AML CFT Roundup 2025: What changed, and what comes next In this episode of Integrity Insights, Filip is joined by Jennifer Hanley-Giersch to review the biggest AML/CFT developments of 2025. They discuss why the year marked a shift from incremental updates to structural change, driven by AMLA’s launch, preparation for the EU Single Rulebook, tougher sanctions expectations, and a renewed focus on terrorist financing. Key themes discussed AMLA and the EU Single Rulebook  Although the regulation applies from July 2027, firms face earlier deadlines. From October 2026, national supervisors will collect new risk and controls data to feed AMLA’s risk-scoring model, forcing many institutions to remediate data gaps.FinTech and RegTech under pressure  Supervisors reported rising risk from FinTechs, often linked to weak governance and immature controls. Jennifer highlights that many serious failures involve poorly implemented RegTech tools and lack of expertise.Germany: BaFin guidance and FIU progress  BaFin’s updated guidance increased expectations around risk assessments (including separating money laundering and terrorist financing risk), residual risk, outsourcing oversight, AML officer responsibilities, and customer data update cycles. The German FIU also reported fewer but higher-quality STRs, with more referrals to law enforcement.Terrorist financing and crypto enforcement  Crypto remains a major risk area, but 2025 showed stronger enforcement momentum, including disruption of terrorist fundraising and takedowns of anonymisation infrastructure such as mixers.Sanctions and circumvention  The episode highlights evolving circumvention models linked to Iran and Russia, and the continued willingness of EU and US authorities to impose substantial penalties where firms knowingly facilitate sanctioned interests.Cyber fraud and operational resilience  They close with the growing impact of cybercrime and DORA-driven supervision of critical ICT providers, reinforcing that resilience is now a core component of financial integrity.Key takeaway: 2025 accelerated the move toward centralised supervision, higher data expectations, and closer links between AML, sanctions, crypto, and cyber resilience. Related content:  AMLA's work program: https://www.acams.org/en/opinion/amlas-work-program-and-its-enhanced-oversight-of-casps  Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    43 Min.
  6. Belgium Leading the Way in the Fight Against Money Laundering in European Football

    17.12.2025

    Belgium Leading the Way in the Fight Against Money Laundering in European Football

    In this episode of Integrity Insights, host Filip Brokes is joined by Professor Niels Appermont, a professor of economic law at Hasselt University in Belgium, and an expert in sports law. Neils discusses his research into money laundering in football, with a particular focus on Belgium’s fight against corruption and the broader challenges of enforcing anti-money laundering (AML) regulations in the sport. Niels shares insights into the Operation Zero scandal, a 2018 Belgian investigation that exposed widespread corruption, money laundering, and match-fixing in professional football. The investigation led to reforms in Belgium's legal framework, including the introduction of AML regulations for football clubs. Key themes discussed: The scope of money laundering in football: Neils explains how football has long been a target for illicit financial flows, with many clubs and agents using shell companies, false invoicing, and match-fixing to cover up corruption and illegal activities.The Belgian response: After Operation Zero, Belgium introduced AML regulations that cover professional football clubs, making them responsible for client identification, beneficial ownership checks, and monitoring potentially suspicious transactions.Key challenges: Neils discusses the practical difficulties Belgian football clubs face when implementing AML measures designed for the financial sector. These include issues with defining who qualifies as a “client” and dealing with the complexity of football transactions such as player transfers and sponsorship deals.International lessons: We also compare Belgium’s experience to the upcoming EU-wide AML regulation for football clubs, set to take effect in 2029. Neils explains the key differences and areas where Belgium has been a pioneer in implementing AML measures in football.Key Takeaways: Money laundering in football is a significant problem, but it's hard to quantify due to the opaque nature of the sector.Belgium's proactive stance on AML in football makes it one of the few countries in the EU to regulate football clubs under AML obligations.Football clubs face unique challenges when trying to implement AML measures due to the complex nature of football transactions and the international scope of the sport.The upcoming EU-wide AML regulations for football clubs could lead to a fragmented approach that may not fully address the sector’s risks.Listen now to explore the intersection of football, corruption, and financial crime and learn more about the evolving regulatory landscape in European football. Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    33 Min.
  7. Why Real Estate Remains a Magnet for Dirty Money

    25.11.2025

    Why Real Estate Remains a Magnet for Dirty Money

    In this episode of Integrity Insights, Filip is joined by Michael Hornsby and Elisabetta Marinoni, researchers working with Transparency International and the Anti-Corruption Data Collective (ACDC), to discuss their new study: the Opacity in Real Estate Ownership (OREO) Index. The conversation explores how opaque real estate ownership structures enable corruption and money laundering, why data and legal frameworks both matter, and what their assessment of 24 jurisdictions reveals about global weaknesses in this sector. Key themes discussed: Why real estate matters for financial crime Real estate remains a preferred vehicle for laundering illicit funds. High-value transactions and the ability to hide behind corporate structures make it attractive to corrupt actors and criminals. What the OREO Index measures The index evaluates 24 jurisdictions, including G20 economies and major financial hubs such as Hong Kong, Singapore, Panama and the UAE. It assesses two pillars: Data – the availability, completeness and openness of property and ownership data.Legal framework – the strength of AML rules governing real estate transactions and professionals.The biggest loophole: missing beneficial ownership data Most countries do not collect beneficial ownership information when property is registered. This means properties can be owned anonymously through companies, especially foreign companies, making it extremely hard for authorities or journalists to trace real ownership or identify patterns of suspicious acquisitions. Cross-border gaps and obstacles for investigators Foreign companies can often buy property without any local presence, meaning no local BO disclosure. Investigators must then rely on the rules—and cooperation—of the company’s home jurisdiction, which is often limited or opaque. Cash purchases and absence of gatekeepers Some countries allow property purchases in cash and do not require involvement of notaries or lawyers. This bypasses banking-sector AML controls and removes an important oversight layer. Uneven AML obligations for real estate professionals While most countries extend AML requirements to real estate agents, developers and lawyers are often excluded, creating entry points for money laundering. In some jurisdictions, lawyers can even refuse to submit suspicious transaction reports due to client-privilege provisions. Weak supervision and fragmented oversight Supervision is often fragmented across many bodies—Germany, for example, has over 300 supervisory authorities in the non-financial sector—making consistent enforcement difficult. How jurisdictions compare South Africa ranks high on paper, but enforcement gaps remain.Germany scores well legally but poorly on data transparency.Singapore and Hong Kong perform relatively well, though Hong Kong maintains weaker BO rules.The UAE scores poorly, reflecting high anonymity and the “open door” model that has historically attracted illicit funds.Future outlook: risks of backsliding Despite years of debate, there is still no global consensus that beneficial ownership transparency in real estate is essential.  Read the full report here: https://www.transparency.org/en/publications/opacity-in-real-estate-ownership-index-2025  Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    32 Min.
  8. Money Laundering-as-a-Service: The Booming Business of Dark Web Money Laundering Services

    16.10.2025

    Money Laundering-as-a-Service: The Booming Business of Dark Web Money Laundering Services

    In this episode of Integrity Insights, Filip is joined by Daniel Shkedi, Head of Product Marketing and Strategy at Refine Intelligence, a fraud prevention company. He is also a fraud and threat intelligence researcher specializing in cybercriminal activity on the dark web and Telegram. His publications cover a wide range of topics, including online fraud prevention (in banking, eCommerce, and payments), identity validation, emerging threats in underground forums, and AI-driven fraud and eCrime. The conversation dives deep into the emerging field of Money Laundering as a Service (MLAS) and how cybercriminals are adapting their operations. Daniel provides insights into his research, the typologies of money laundering services offered on the dark web, and why financial institutions need to pay attention to this growing threat. Key themes discussed: Money Laundering as a Service (MLAS) Daniel describes his recent project, where he mapped out how organized criminal groups provide money laundering services to fraudsters on platforms like Telegram and the dark web. This “business” mirrors legitimate financial services in sophistication and scale, making it a rapidly growing problem for financial institutions. Typologies of Money Laundering Through his research, Daniel identified several key typologies of money laundering services, including: Bank Drops: Rented or sold bank accounts used for cash-out services.Bank Loaders: Criminals who move funds onward to bank drop accounts.End-to-End Money Laundering Services: Criminal enterprises offering full money laundering packages, including layering and integration.Shell Companies and Insider Services: Fraudsters offering to set up fake companies or bank insiders selling stolen financial data.Street-Level Cash Outs: Basic services where criminals withdraw funds using stolen or fraudulently obtained bank accounts.Global Scope of Money Laundering Daniel shares his findings on how these services are not limited to a single region, but are a global phenomenon. The services are available across North America, Europe, Latin America, Asia, and the Pacific, with different nuances depending on the jurisdiction. Why Institutions Should Care Beyond regulatory compliance, Daniel emphasizes that money laundering and fraud expose financial institutions to serious reputational risks, financial losses, and operational disruptions. Criminal enterprises are evolving, and financial institutions must adapt by building proactive threat intelligence programs. The Role of Threat Intelligence Daniel outlines how threat intelligence plays a pivotal role in understanding fraud enablers, monitoring their infrastructure, and predicting where future attacks might come from. By gathering data from multiple sources, including the dark web and Telegram, financial institutions can develop comprehensive threat intelligence strategies to stay ahead of cybercriminals. Connect with Us: LinkedIn: https://www.linkedin.com/showcase/integrity-insights/?viewAsMember=trueBerlin Risk Linkedin: https://www.linkedin.com/company/berlinrisk/?viewAsMember=trueWebsite: https://berlinrisk.com/

    33 Min.
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Integrity Insights is a podcast from Berlin Risk, a Berlin-based corporate intelligence and compliance advisory firm. In the podcast, we cover the latest developments in the fields of financial crime, political risk, sanctions, open source investigations and much more. The podcast is hosted by Filip Brokes, consultant at Berlin Risk. 

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