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Dissent as Fourth EU ML Directive nears adoption
The Fourth EU Money Laundering Directive (4MLD) edged closer to adoption on 20 April after the EU Council of Ministers formally approved a three-way ‘trilogue’ deal that Council, European Parliament and European Commission negotiators..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
Russian dealings – a safe passage
Sanctions against Russia over its involvement in the Ukraine conflict are complex but navigable: Brian Zimbler and Vasilisa Strizh of the Moscow office of Morgan Lewis take the helm.
Well over a year has passed since the US, European Union..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
Case to answer: R v Rogers - implications for practitioners
The Court of Appeal (Criminal Division) decided in R v Rogers [2014] EWCA Crim 1680 that a UK court has jurisdiction to convict a defendant of money laundering in circumstances where all of the conduct constituting the money laundering takes place..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
A matter of control – Chinese money flows
Chinese citizens are subject to a US$50,000 annual limit on foreign currency purchases, which invites the wealthy elite, whether their funds are legally come by or not, to seek inventive ways to move money out of the country. Gao Fu Mao, in Beijing,..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
Les jeux sont faits: money laundering and physical casinos
Stacked chips on green baize, the clickety-clack of a metal ball bouncing round the roulette wheel, impassive card dealers and glamorous if edgy looking clientele: the high roller with questionable cash to splash is a stock movie character but is..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
UK regulator issues thinly veiled threat on derisking
The UK Financial Conduct Authority rattled the enforcement sword on 27 April with a statement that it will look at whether firms’ approaches to derisking give rise to “consumer protection and/or competition issues” in the course of..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
Risk appetite – a question of definition
Effective AML is predicated on a clearly defined risk appetite. A panel of leading practitioners at the ACAMSmoneylaundering.com AML & Financial Crime Conference in Miami delved into the mechanics of how to assess risk and then communicate it...
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
Iran sanctions relief – on the near horizon
Iran may, finally, be coming in from the cold, edging towards a deal with the ‘P5+1’ powers over its nuclear programme. Covington lawyers analyse the parameters set for an agreement by the end of June 2015.
On 2 April 2015, the..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015
HSBC monitor cites management resistance amidst progress
Senior managers at HSBC’s US global banking and markets unit obstructed a 2014 internal KYC review “in a manner that caused the final audit report to be more favourable to the business than it would otherwise have been,” the..
Online Published Date:
01 May 2015
Appeared in issue:
223 - 30 April 2015