As firms continue to navigate the labyrinthine minefield of legislation and regulation and claw their way up the evolutionary ladder of compliance with standards that appear to have moving goal posts, ‘tone from the top’ has never been more important.....More
In November 2017, Transparency International (TI) published the report Hiding in Plain Sight which further highlighted the attractiveness of UK Plc to those that wish to launder the proceeds of corruption or value of other criminal origin.
Whilst the CDD process can be considered as a process with inputs and outputs I would like to put forward another way to think about this subject area. As my students know, I love a good analogy and the parallels I would like to draw with CDD is the building of a house.....More
On Monday 26 June 2017, by the skin of its teeth, the UK enacted the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs 2017). Dragging its heels, somewhat unusually for UK Plc, there were a few tweaks but no real surprises between the draft MLRs and the final version with five key changes made:
In the UK Anti-Corruption Plan, published on 18 December 2014, the Government committed to carrying out a review of the suspicious activity reports (SARs) regime contained in the Proceeds of Crime Act 2002 (PoCA) and the Terrorism Act 2000 by July 2015. The purpose of which is to develop ways of better identifying money laundering and the financing of terrorism, and to prevent the movement and use of the proceeds of crime. The Home Office has, therefore, launched a ‘Call for Information’ in relation to SARs and firms are invited to respond to various questions.
Automated systems are great, but it still comes down to people to understand the information and make the appropriate decisions so, as an institution’s first line of defence and arguably its greatest asset, this is where we should be seeing significant investment.
In May 2013 Barclays said it would close the bank accounts of Somali remittance company Dahabshiil and a number of other money transfer companies (between 100 and 250 depending on what you read). This was a considered decision as part of Barclays’ risk-based approach to its obligations under UK anti-money laundering legislation.....More