Money Laundering Bulletin

Ten years on

Steve Wilkinson, Head of the Proceeds of Crime Centre, Serious Organised Crime Agency (SOCA) is still following the arc of asset recovery and financial crime investigation in the UK after nearly 25 years in law enforcement. Now responsible for the unit that accredits some 3,500 financial investigators, he’s looking forward to the launch of the National Crime Agency (NCA) on 1 October 2013, he told delegates to the 10 Annual Institute of Money Laundering Prevention Officers conference in Brighton.

Tracing and Recovery, Training, Law Enforcement, Assets Recovery, Legislation & Guidance, Practice Findings, Europe

The slave trade: tracking human traffickers

People, often with limited opportunities in their home country and who hope for better overseas, represent massive profit potential to those willing to move and exploit them. Significant sums will, inevitably, pass through financial institutions and work is underway, reports Paul Cochrane, on human trafficking indicators and creative identification of associated account-holders.

Jurisdictions, Monitoring, Typologies, Predicate Crimes

Cyprus AML flaws exposed in Moneyval review

Cypriot banks’ anti-money laundering controls have ‘systemic weaknesses’ according Moneyval and Deloitte. A confidential summary report, leaked on the Stockwatch website [1], goes some way to explain the prolonged bailout negotiations, with Germany, notably, vocal in its criticism of governance in the island’s financial institutions.

Customer Due Diligence, Practice Findings, Supervisors, Europe

MEPs criticise EU governments over intelligence-sharing to fight illicit finance

A joint meeting of national and European parliamentarians (MEPs) in Brussels last week [7 May] lambasted European Union (EU) member governments for foot-dragging in the fight against organised crime and money laundering in particular.

Law Enforcement, Government and International Bodies, Practice Findings, Europe

Enforcement evolves

Catastrophic failures in compliance or business override to take on customers anywhere along the risk spectrum – whichever, humiliated regulators on both sides of the Atlantic are determined not to be laughed at again by those they supervise. A new era in punishment is promised by their approach at both policy and case level, says Timon Molloy, while the outlook on law enforcement (in the UK) is, perhaps, more welcome to firms.

Law Enforcement, Cases, Practice Findings, Supervisors, Europe, North America
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PEPs

EFG Private Bank fined £4.2m for lax higher risk customer controls

EFG Private Bank Ltd (EFG) has been fined £4.2m by the Financial Conduct Authority (FCA) for AML control failings around higher risk customers, including politically exposed persons (PEPs). The UK subsidiary of Swiss EFGI Group is the third institution, after Coutts [1] and Turkish Bank (UK) Ltd [2], to be fined by the UK regulator following its 2011 thematic review of banks’ approach to managing high risk money laundering situations. [3]

Customer Due Diligence, Monitoring, PEPs, Banks, Cases, Supervisors, Europe

Treasury forecasts

Sanctions, Customer Due Diligence, Payments, PEPs, Trust and Company Service Providers, High Value Dealers, Government and International Bodies, Legislation & Guidance, Europe
Money Laundering

Changing direction

The waiting over, Edward Jones, MLRO at Radleys, and his team, pore over the draft Fourth EU Money Laundering Directive and meditate the new Financial Action Task Force focus on effectiveness. Sue Grossey takes detailed minutes.

Jurisdictions, Training, Government and International Bodies, Legislation & Guidance, Europe

Derrick ponders… Emi’s employment

What happens to suspicions when you change jobs? Derrick Paterson considers a sequence of employments that raises some questions.

Reporting, Training, Europe
Risks and Controls

British territories in Caribbean to automate foreign account data exchange

British Overseas Territories will share information on bank accounts held by foreign nationals of five European countries with their revenue authorities under an agreement that HM Treasury says marks “a turning point in the fight against tax evasion and illicit finance.”

Customer Due Diligence, Tax Evasion, Europe, Latin America and Caribbean

Checking on Compliance – AML and Audit

The organisation chart looks right, workflows and systems are logically drawn, policies and procedures in place but the board wants to know if the firm’s AML model is fit for purpose, so does the head of compliance. Audit’s role in assurance testing was explored by practitioners at the 18th Annual AML and Financial Crime Conference in Miami. Timon Molloy reports.

Risks and Controls, Monitoring, Training, Practice Findings
Industries

Rock-steady – Gibraltar

Online gambling and offshore accounts – both signal risk but the island territory of Gibraltar is working hard to stay clean finds Rob Stokes in this report from Malaga.

Trust and Company Service Providers, Casinos, Practice Findings, Europe

Fourth Directive – a way to go

The European Commission’s proposals for a Fourth Money Laundering Directive (4MLD) announced last week [5 February 2013] were held up for the best part of a year to avoid clashing with the revised Recommendations from the Financial Action Task Force (FATF). Not everybody is convinced the package was worth the wait, says Alan Osborn.

PEPs, Tax Evasion, Trade Finance, Trust and Company Service Providers, Legislation & Guidance, Europe
Terrorist Financing

Collateral damage – terrorist asset freezing impact

Terrorist asset freezes impose an immediate financial sentence on suspects but it doesn’t always end with removal from a sanctions list, says Robert Stokes. Additional reporting by Carmen Paun.

Terrorist Financing, Europe, North America

Sight lines: US terrorist finance investigations & EU data protection

US terrorist finance investigators are able to examine SWIFT data on EU citizens’ account transactions, subject to oversight: are the checks and balances working? Carmen Paun spoke to Gilles de Kerchove, EU counter-terrorism coordinator, in Brussels.

Terrorist Financing, Europe, North America
Legal / Regulatory

Psychology & profiling: money launderers & anti-money launderers [part two]

Launderers are not of a single type as David Thomas showed in part one of his criminological perspective; anti-money launderers are equally diverse. An effective AML strategy, built on profiling, needs, he says, to reflect the differences.

Money Laundering, Training, Typologies, Predicate Crimes, Practice Findings

Through the minefield

US and international leading AML/STF professionals tackled major issues of the day – sanctions, board engagement, trade based money laundering, data protection and shell corporations - in a series of highly instructive panel sessions at the ACAMS moneylaundering.com 18th Annual AML and Financial Crime Conference in Miami. Timon Molloy took notes.

Sanctions, Training, Trade Finance, Legislation & Guidance, Practice Findings, Europe, North America, Corporate Vehicles
Sanctions

Iran dances the sanctions side-step

Iran is labouring under United Nations, US and European Union sanctions. Last year the US tightened the screws further by a series of executive orders: as President Barack Obama said following his re-election in November 2012: “We’ve imposed the toughest sanctions in history.” Circumvention might also be tougher than ever but even so, some jurisdictions are not cracking down as much as Washington would like. Paul Cochrane reports from Beirut.

Sanctions, Middle East, North America

Change management – OFAC on sanctions

“Never before have we seen these tools being so sought after by top policymakers in the cabinet - the White House - to deal with threats, with the ultimate objective to avoid seeing a need for military involvement,” Adam Szubin, Director of the US Office of Foreign Assets Control (OFAC) acknowledged in his keynote address to the ACAMS moneylaundering.com 18th Annual AML & Financial Crime Conference in Miami, Florida.

Sanctions, Government and International Bodies, Legislation & Guidance, Asia-Pacific, Middle East, North America