Enforcement: Ten Secrets To Building A World-class Financial Crime Function

Commonwealth Bank has been fined A$700 million for moving A$8.9 billion through its flawed smart ATM channel in breach of AML/CTF laws.

Westpac is in the middle of a case that will exceed those figures, with A$11 billion in disputed transactions and 23 million alleged breaches.

National Australia Bank (NAB) has been buried in an uplift program for more than 18 months, flushed out its management team and is bracing investors for potentially the biggest fine in Australian corporate history.

Amid these challenges the chief executives of all three banks have stepped down while the complicated "uplift" work takes place.

Australia and New Zealand Banking Group (ANZ), on the other hand, released a statement last week saying it "is not aware of any impending litigation from [the Australian Transaction Reports and Analysis Centre] AUSTRAC". The bank has been fielding calls from skittish institutional investors following Westpac's anti-money laundering litigation, some of which may potentially have had links with child exploitation.

ANZ is benefiting from a decade-long commitment to its financial crime compliance framework, which began a decade earlier when it had an A$6.95 million run-in with the fearsome U.S. Office of Foreign Assets Control (OFAC). As Australian banks stare down the barrel of A$1 billion-plus AML/CTF fines, ANZ's penalty seems like a bargain with the benefit of 2020 hindsight.

In view of the challenges facing Australia's banks, Thomson Reuters Regulatory Intelligence has compiled the "top ten" management lessons that can be drawn from ANZ's world-class approach to managing financial crime risks. The checklist applies equally well to banks from around the world that find themselves operating in an environment of heightened financial crime enforcement risk.

1. Hire effective people and hold onto them. Let them understand the business. Get recruitment and incentives right.

Guy Boyd, ANZ's head of group compliance, has been with the bank since 2006 in a range of financial crime and sanctions-related roles. His 13-year history with the bank reflects a strong corporate culture. This stability of tenure has given him time to forge strong relationships with key decision makers and to give them confidence that he understands the business's key risks comprehensively.

Vin Danwar, a risk management expert with the Country Fire Authority in Victoria, said choosing the right people and then investing in their success was crucial.

"Compliance teams need strategic big-picture thinkers, not merely textbook tick-box scholars. Please start hiring people [with] diversified experience who can think broadly and strategically with potentially global experience who have seen other parts of the world.

"Most the risk and compliance teams have little to zero experience in designing and implementing controls that are practical and able to be monitored. Mere checklists and risk summaries will not make any organisation safe," Danwar said.

2. Resource the compliance team properly. Give managers the talent they need to protect the organisation, customers and the board. Respect their expertise and listen to their advice.

When respect and trust flourish in an organisation, problems are less likely to fester. Middle managers will have the confidence to escalate important issues but not bury their line managers in defensive "incident reports".

"All of these points relate to a good culture that is set by the board and executive. Treating your risk teams as assets, rather than a prescribed must-have drain on resources, is a prerequisite," said Stuart Norbury, principal at Lawson Delaney.

Tapas Shyam, assistant vice-president at tech company Intellect Design Arena in Sydney, said managers should treat the AML/CTF team like a revenue centre rather than a cost centre. Adequate budgets for mission-critical technology spending to manage operational and regulatory risks were essential, he said.

"Most banks wait for the regulator to give them a slap on the wrist or a punch to the face before allocating money to initiatives aimed at beefing up compliance processes," Shyam said. "This is a classic recipe for disaster where banks keep chasing their tail only to get slapped by another billion-dollar fine on the next issue as soon as they wrap up remediation on the first."

3. Engage with regulators at every opportunity.

Government agencies are often regarded as monolithic entities, but they are ultimately made up of individuals making decisions. Building respect, trust and open lines of communication is the best way to ensure that "spot fires" are managed before they turn into existential threats.

One way for firms to foster a strong relationship is to support industry outreach events organised by regulators by sending along senior representatives. This is something ANZ has always done; not to engineer regulatory relations, but because it has an AML team that deeply respects the regulator and wants to learn. It shows.

Skye Bowie, a lawyer and compliance expert at QSuper Group, said this was a simple but symbolic gesture.

"I agree with the engagement with regulators. It sends a positive message that your organisation is engaged with the regulator and allows an organisation to anticipate future directions and priorities," Bowie said.

"I'm aware that some don't attend regulator events to keep a low profile."

4. Go above and beyond. AML and CTF is a passion, not just a job.

Financial crime compliance needs to be treated as a critical company asset, and leaders should encourage their teams to innovate.

Bhawna Bhardwaj, associate director of AML at National Australia Bank (NAB), said this passion for the work is crucial in effective teams. Realistically, however, not all team members can be inspired all the time. A good proxy for this is to select and support people who want to keep on learning.

"You can't have everyone carrying the same passion. We need all kinds of people to build a great team. What I would like to add is: be a person who wants to learn and evolve," Bhardwaj said.

5. Participate in public-private partnerships in a meaningful way, not just to build relations with regulators.

Public-private partnerships to fight financial crime, such as the Fintel Alliance, are the future of effective AML, and help to build a genuine partnership with the financial intelligence unit.

Luke Raven, compliance manager at Airwallex in Sydney, said this was another area where ANZ had shone.

"ANZ's leadership around engaging with AUSTRAC and being a key part of the Fintel Alliance, which particularly focused around tackling the emotive child exploitation material typology, is inspiring. It's great to have [one of the] 'big four' leading the way in these grim times," he said.

6. Engage the financial crime compliance team in commercial decisions at an early stage.

Matt Maddocks, senior consultant at ORC Professional Services in Singapore, said it was evident during his five years with ANZ in Asia that a financial crime compliance ethos was embedded across the bank. He said this proactive approach meant the business units actually wanted to work with the financial crime team.

"Every single person I liaised with in a junior or senior capacity at FinCrime ANZ took their role very seriously. So kudos to them," he said.

7. Be bold when it is warranted, cautious when required. A great MLRO knows the difference.

Despite the "move fast and break laws" mantra of the fintech era, it is not always essential to be first to market. When lines of trust and communication have been established, it is much easier for senior managers to rely on their money laundering reporting officer's (MLRO) advice.

Dr Elena Stephens, a legal expert with Axiom in Chicago, said banks should not be railroaded into becoming innovators at the expense of traditional qualities such as stability and prudent risk management.

"I would add: stop stretching your reach. Downsize if the service is not profitable. We don't need innovation at all costs. The banks have always been conservative in their approach to business and should continue to be that way," Stephens said.

8. Treat the financial crime compliance team as custodians of the bank's most valuable assets: trust and brand.

Conservatism is not always a bad thing. Agility and innovation are vital in the disruptive age of technology, but firms should not jettison the counterbalancing qualities of knowing their strengths and playing to them. When a trusted financial crime risk expert urges caution, it makes a lot of sense to listen.

Dean Wyatt, head of financial crime at Indue in Brisbane, said ANZ's financial crime compliance function exemplified these qualities.

"Whenever I've spoken to senior folks at ANZ regarding financial crime they seem switched on — especially in the governance component. They may not be the best innovators of the tech world, but they aren't leaving chasms of International Funds Transfer Instructions (IFTIs) unreported in their wake," he said.

ANZ's decision to delay the launch of real-time payments on the New Payments Platform (NPP), despite falling behind its competitors, was a good case in point, he said.

"I remember clearly as the analytics teams all met in advance to discuss the NPP. It was very clear they were concerned about NPP and sanctions," Wyatt said.

9. Foster a team of AML entrepreneurs.

Financial crime compliance is not law enforcement. It is ultimately a business support role. Strong AML teams lead to corporations with a conscience, but they also have a deeply entrepreneurial spirit. This involves thinking differently, being prepared to support commercial teams and avoiding any semblance of the old "business prevention department" stigma.

There are times to say, "We simply can't do this." But having a commercial mindset and being a good communicator means this message stands a greater chance of being well received, and respected.

Anti-money laundering teams need to support their business' revenue engines. Only by doing this will they win the front-line's trust.

Sam Scerri, senior manager at Deloitte, said this positive mindset had been evident when he worked at ANZ.

"As a proud ex ANZ banker who has been involved in some fairly 'interesting' payment events, one thing was always clear. The MLRO system and support provided to bankers by the financial crime team has always been a first-class partnership," Scerri said.

10. Trust ... but verify

Senior managers and boards need to listen to their risk teams but be willing to challenge and audit what they say. They must create an environment where people feel able to challenge ideas respectfully and without causing offence. A culture of healthy scepticism, with the opportunity to raise questions both down and up the management chain, could perhaps have insulated several major banks from regulatory disaster.

As the Australian Prudential Regulation Authority report into risk culture at the Commonwealth Bank pointed out, strengths can easily become weaknesses if they are not tempered. Likewise, even a culture of positive reinforcement can prove fatal if people are not free to criticise, or to tell the proverbial emperor he is somewhat under-dressed.

Mark Linter, an independent executive risk adviser in Melbourne, said ANZ did a good job of striking this balance.

"Certainly, smart, strong individuals work there. Risk and compliance management is a non-stop and continuous process, not a task. Reassurance on no exposures should be readily available but it's never a bad thing to check," he said.

Links to Regulatory Intelligence commentary on the recent Australian AML/CTF cases:

RADIO:

https://www.abc.net.au/radionational/programs/themoney/follow-the-money:-westpacs-money-laundering-scandal/11746744

https://www.2gb.com/westpac-accused-of-breaching-anti-money-laundering-laws/

PRINT:

https://www.abc.net.au/news/2019-11-24/story-behind-westpac-paedophile-bankroll-supporting-tax-dodge/11731928

https://www.afr.com/wealth/personal-finance/the-price-of-banks-becoming-crime-fighters-20191129-p53ffb

https://www.afr.com/companies/financial-services/dentons-the-law-firm-behind-afterpay-s-advice-20191125-p53dxt

https://www.afr.com/companies/financial-services/westpac-shut-remittance-firms-over-money-laundering-risk-20191126-p53e3w

https://www.afr.com/companies/financial-services/afterpay-money-laundering-non-compliant-20191125-p53dqh

https://www.afr.com/property/residential/international-body-suspends-anti-money-laundering-law-evaluations-20191118-p53bid

https://www.michaelwest.com.au/swerving-swift-the-story-behind-westpacs-money-laundering-calamity-aundering-calamity/

https://www.michaelwest.com.au/fatf-caves-as-australia-keeps-propping-up-property-market-with-black-money/

https://www.thesaturdaypaper.com.au/news/law-crime/2019/11/30/westpac-austrac-fallout-spreads/15750324009165

Written by:

Thomson Reuters Regulatory Intelligence and Compliance Learning
Contact
more
less

Thomson Reuters Regulatory Intelligence and Compliance Learning on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.