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                                                Pooled Client Accounts: the final answer?
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    John Binns(+44 (0)20 7430 2277,jbinns@bcl.com) is a partner and specialist in money laundering and financial crime at BCL Solicitors LLP in London.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        06 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                ‘Inexcusable’ errors by Deutsche Bank in Epstein relationship and correspondent banking AML breaches bring US$150m fine in New York
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Deutsche Bank will pay US$150 million to the New York Department of Financial Services (DFS) for due diligence and monitoring failures in its relationship with convicted sex offender Jeffrey Epstein, also for not adequately addressing anti-money..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        08 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Signet Bank fined nearly €1 million in Latvia for AML breaches
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    SignetBank is to pay a €906,610penalty in Latvia for customer due diligence and transaction monitoring failings.[1] An inspection by the Financial and Capital Markets Commission(FCMC) found the bank had not taken adequate steps to verify beneficial..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        17 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Romania and Ireland fined over late Fourth EU ML Directive implementation
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    By Sara Lewis, in Brussels
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        20 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Magnitsky sanctions: a storm in a teacup?
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    John Binns (+44 (0)20 74302277, jbinns@bcl.com) is a partner andspecialist in money laundering and financial crime at BCL Solicitors LLP inLondon.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        20 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Russian elite and criminal money fully integrated in UK, Parliament committee finds
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The UK is a “top Western intelligence target” for Russia, according to the UK Parliament Intelligence and Security Committee, which has examined the threat from illicit financial flows from that country as well as its espionage and cyber..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        21 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                New Zealand High Court fines two remitters NZ$7.6m for AML breaches
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    OTT Trading Group and MSI Group, New Zealand-based money services businesses, have been fined NZ$3.1m and NZ$4.485m, respectively, over failure to conduct anti-money laundering risk assessment and for “inadequate or non-existent [customer] due..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        23 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Eyes always open [2] – KYC 'now'
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Dermot Corrigan (+44 7710 266333, dermot.corrigan@smartkyc.com) is CEO of smartKYC.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        28 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Global exchange – inside the Egmont Group
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Interview by Keith Nuthall.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        28 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Sparkasse Bank fined €217,000 in Malta for AML breaches
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Sparkasse Bank has been fined €217,000 for anti-money laundering failings by Malta’s Financial Intelligence Analysis Unit. The FIAU uncovered a series of breaches during an onsite inspection of the Austrian deposit-taker, including customer risk..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        29 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Ex-Coutts AML officer convicted in Switzerland over 1MDB reporting failures
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    A former Coutts anti-money laundering officer was found guilty, on 31 July [2020], by a Swiss court of failing to act on red flags around transactions by Jho Low, alleged orchestrator of siphoning off up to US$4.5bn from 1MDB, the Malaysian..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        31 July 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Annual return – UK National Crime Agency reports
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Josef Rybacki (+44 (0)20 7872 1517, josef.rybacki@wilmerhale.com) is an associate in WilmerHale’s UK White Collar Defence and Investigations practice.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        10 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Have Unexplained Wealth Orders hit the rocks?
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    John Binns (+44 (0)20 74302277, jbinns@bcl.com) and Michael Drury(+44 (0)20 7430 2277, mdrury@bcl.com) arepartners at BCL Solicitors LLP, specialising in financial crime, includingmoney laundering, civil recovery, and unexplained wealth.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        10 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Sparing the rod – UK AML supervision
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Late reporting carries regulatory sanction unless, that is, you’re a regulator, apparently. Or maybe publication in August 2020 of the review of UK AML supervisors’ performance for the period 6 April 2018 to 5 April 2019 [1] is solely down to HM..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        11 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                FIMBank fined in Malta for country risk and monitoring flaws
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    FIMBank has been fined €168,943 by Malta’s Financial Intelligence Analysis Unit (FIAU) for risk assessment and monitoring breaches. [1]An onsite inspection in 2018 found that the bank’s country risk assessment model used in profiling ultimate..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        12 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Interactive Brokers fined US$38m: under-resourced AML; suspected microcap manipulation unreported
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    By Sara Lewis
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        13 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Purplebricks estate agency reddened by UK£266,793 fine for AML breaches
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Online estate agency Purplebricks has been fined UK£266,793 by HM Revenue & Customs for breaches of the Money Laundering Regulations 2017.The regulator found deficiencies in “policies, controls and procedures, conducting due diligence and timing..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        19 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Qualified positive – the UK economic crime levy
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Alun Milford (+44 (0)20 7369 3818, amilford@kingsleynapley.co.uk) is a criminal litigation partner at Kingsley Napley LLP. Previously he was General Counsel at the Serious Fraud Office, the Crown Prosecution Service’s Head of Organised Crime, its Head of Proceeds of Crime and Revenue and Customs Prosecutions Office’s Head of Asset Forfeiture Division.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        20 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Opinion: China is the world’s biggest money laundering threat
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    John A. Cassara retired after a 26-year career as a U.S. intelligence officer and Special Agent for the Department of Treasury. He is a speaker and consultant and is on the Board of Directors of Global Financial Integrity. Cassara has written countless articles and five books on money laundering and threat finance. Additional information is available at www.JohnCassara.com
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        20 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Occupational hazards: the National Risk Assessment
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Susan Grossey may be contacted on +44 (0)1223 563636, susan@thinkingaboutcrime.com, www.thinkingaboutcrime.com
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        25 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Out of control – the Commerzbank London case
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Denis O’Connor, a Fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment, was a member of the British Bankers’ Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group’s Board and Editorial Panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the UK and abroad.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        25 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Undaunted - fintechs forge on
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Energetic and determined to shake upfinancial services, fintechs are innovating in AML as well. Paul Cochranekeeps pace with the latest developments. The world’s fast-growing digital banking andpayments sector requires regulatory compliance software..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        25 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                China – set out
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The People’s Republic of China may be vying for premier position in global economic rankings but, despite a recent rise in enforcement activity, it still has far to go in the anti-money laundering league, finds Jens Kastner.China is expanding..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        25 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Crown Dependencies – ownership and control
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Britain’s three Crown Dependencies – theIsle of Man, Jersey and Guernsey – are preparing to draft legislation to ensuretheir respective beneficial ownership registers are open to the public, even asthey steer between UK and EU influence post Brexit,..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        25 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020
                                                    
                                                
                                            
                                            
                                                Go East – salaries and prospects in Asia
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Leadership in global trade may be tipping in favour of the Far East but governance is playing catch-up – good news, one would think, for anti-money laundering compliance. Poorna Rodrigo, Keith Nuthall and Julian Ryall go into the job market.Hong..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        25 August 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            276 - 06 July 2020