Money Laundering Bulletin

Timon Molloy, Editor (timon.molloy@informa.com)

Asset recovery has come a long way in nearly ten years since the Proceeds of Crime Act 2002 took effect. Criminals are poorer by a billion pounds, writes Tristram Hicks, and cash remains their weakest link.

A member of the House of Lords has been reported as saying “Taking dirty money from foreign despots is unacceptable behaviour…” whilst the Joint Money Laundering Steering Group’s guidance says, “Establishing whether individuals qualify as PEPs [politically exposed persons] is not always straightforward and present difficulties.” Derrick Paterson reflects on the problems that firms can face with foreign individuals.

How do you demonstrate that your senior management are committed to AML? Denis O’Connor, managing director with the financial crime portfolio at the Association of Financial Markets in Europe has a strong personal view.

The Greek economic crisis may provide the perfect backdrop for money laundering, writes Michael Kosmides from Athens. Dr Ioannis Filos, professor of Auditing at Panteion University in Athens and director of the Greek chapter of the European Business Ethics Network (EBEN), has no doubts: “It is obvious... the financial stress is a big incentive for people to get involved in wrongdoing, fraud, corruption.”

The location of the opening sequence of a Bond film is traditionally a good indication of troubled jurisdictions, writes Sue Grossey. In “Dr No” (1962), Sean Connery tracked baddies and Ursula Andress around Jamaica. Roger Moore tackled space in “Moonraker” (1979). In “Die Another Day” (2002), Timothy Dalton surfed onto a beach in North Korea. Pierce Brosnan in “GoldenEye” (1995) infiltrated a Russian chemical weapons facility. And in “Skyfall” (2012), Daniel Craig rides a motorbike over the rooftops of the Grand Bazaar in Istanbul. Yes: Turkey has been promoted to the Bond list of dodgy countries.

Britain’s Crown Dependencies (CDs) - the Channel Islands and the Isle of Man - have always been tricky customers for the world’s anti-money laundering (AML) authorities to get a fix on. Alan Osborn takes the latest soundings.

After a long wait, writes Mark Dunn, the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have finally published guidance to help companies comply with the US anti-bribery & corruption legislation, the Foreign Corrupt Practices Act (FCPA). On its release on 14 November 2012, the two agencies enthusiastically proclaimed, “There may (be) no other area of the law where DOJ or SEC has provided the public with as much information about our enforcement approach and priorities.” Does the guidance meet expectations and provide clarity or is it simply a rehash of existing information from US regulators?