i-law

Money Laundering Bulletin

Laundering & law enforcement: options for UK investigators (& suspects)

John Binns (+44 (0)20 7430 2277, jbinns@bcl.com) is a partner at BCL Solicitors LLP, specialising in money laundering and POCA.
Online Published Date:  01 August 2022
Appeared in issue:  296 - 11 July 2022

English legal entity structure is cloak for criminality, say investigators

The UK may have launched the first public register of beneficial owners of companies in 2016 but one type of corporate vehicle it offers is still wide open to abuse by criminals, according to a joint investigation by the BBC and Finance Uncovered...
Online Published Date:  05 August 2022
Appeared in issue:  296 - 11 July 2022

English legal entity structure is cloak for criminality, say investigators

The UK may have launched the first public register of beneficial owners of companies in 2016 but one type of corporate vehicle it offers is still wide open to abuse by criminals, according to a joint investigation by the BBC and Finance Uncovered...
Online Published Date:  05 August 2022
Appeared in issue:  297 - 03 October 2022

Ukraine-Russia conflict [20] – sanctions: natural resources and tuning measures

Susannah Cogman (+44 (0)20 7466 2580, susannah.cogman@hsf.com), is a partner and Elizabeth Head (+44 (0)20 7466 6443, elizabeth.head@hsf.com) is of counsel at Herbert Smith Freehills.
Online Published Date:  05 August 2022
Appeared in issue:  296 - 11 July 2022

Robinhood Crypto fined US$30m in New York for AML and cybersecurity control breaches

Cryptocurrency exchange Robinhood Crypto, LLC (RHC), a subsidiary of Robinhood Markets, Inc (RHM), the group that also offers commission-free trading on stocks and options to retail investors, has been ordered to pay US$30 million after the New York..
Online Published Date:  05 August 2022
Appeared in issue:  296 - 11 July 2022

LeoVegas pays UK£1.32m to Gambling Commission for AML and social harm failures

Online gambling operator LeoVegas has been fined UK£1.32 million (US$1,554,458) by the UK regulator for ineffective controls to prevent money laundering and protect customers who display problematic behaviour.The firm, which runs leovegas.com,..
Online Published Date:  05 August 2022
Appeared in issue:  296 - 11 July 2022

LeoVegas pays UK£1.32m to Gambling Commission for AML and social harm failures

Online gambling operator LeoVegas has been fined UK£1.32 million (US$1,554,458) by the UK regulator for ineffective controls to prevent money laundering and protect customers who display problematic behaviour.The firm, which runs leovegas.com,..
Online Published Date:  05 August 2022
Appeared in issue:  297 - 03 October 2022

Report card – SARs experience

Suspicious transaction reports (STRs) are frequently criticized as too numerous, costly and contributing little to law enforcement investigations. Rose Pengelly, Paul Cochrane and Keith Nuthall put a lens on filing practice and output.United Kingdom..
Online Published Date:  05 August 2022
Appeared in issue:  296 - 11 July 2022

Report card – SARs experience

Suspicious transaction reports (STRs) are frequently criticized as too numerous, costly and contributing little to law enforcement investigations. Rose Pengelly, Paul Cochrane and Keith Nuthall put a lens on filing practice and output.United Kingdom..
Online Published Date:  05 August 2022
Appeared in issue:  297 - 03 October 2022

Grey zone - Zimbabwe

Rich in natural resources but yet emerging from decades of economic mismanagement, Zimbabwe has turned a corner in tackling money laundering, according to the Financial Action Task Force. Paul Cochrane, in Pietermaritzburg, finds not everyone so..
Online Published Date:  06 August 2022
Appeared in issue:  296 - 11 July 2022

Grey zone - Zimbabwe

Rich in natural resources but yet emerging from decades of economic mismanagement, Zimbabwe has turned a corner in tackling money laundering, according to the Financial Action Task Force. Paul Cochrane, in Pietermaritzburg, finds not everyone so..
Online Published Date:  06 August 2022
Appeared in issue:  297 - 03 October 2022

On the scent – illegal wildlife trade

Criminal dealing in ‘protected’ rare and endangered species is serviced by networks of illicit finance, which are coming under increasing scrutiny, finds Paul Cochrane, in Pietermaritzburg, South Africa. The Financial Action Task Force (FATF) issued..
Online Published Date:  09 August 2022
Appeared in issue:  296 - 11 July 2022

On the scent – illegal wildlife trade

Criminal dealing in ‘protected’ rare and endangered species is serviced by networks of illicit finance, which are coming under increasing scrutiny, finds Paul Cochrane, in Pietermaritzburg, South Africa. The Financial Action Task Force (FATF) issued..
Online Published Date:  09 August 2022
Appeared in issue:  297 - 03 October 2022

FinCrime Curator - August 2022

To really know your enemy, you need someone on the inside. We can't all be law enforcement but next best is wherever possible to learn from their experience: two resources, from Europol and Robert Mazur - 'The Infiltrator' - will help. Veteran..
Online Published Date:  10 August 2022
Appeared in issue:  296 - 11 July 2022

FinCrime Curator - August 2022

To really know your enemy, you need someone on the inside. We can't all be law enforcement but next best is wherever possible to learn from their experience: two resources, from Europol and Robert Mazur - 'The Infiltrator' - will help. Veteran..
Online Published Date:  10 August 2022
Appeared in issue:  297 - 03 October 2022

Ukraine-Russia conflict [21] – sanctions: pinpointing and refinement

3/8/22: The USA is sharpening up its economic measures against Russia, issuing new and amended General Licences, providing clarifications, while also targeting further individuals and businesses for asset freezes. Herbert Smith Freehills review the..
Online Published Date:  10 August 2022
Appeared in issue:  297 - 03 October 2022

Ukraine-Russia conflict [21] – sanctions: pinpointing and refinement

3/8/22: The USA is sharpening up its economic measures against Russia, issuing new and amended General Licences, providing clarifications, while also targeting further individuals and businesses for asset freezes. Herbert Smith Freehills review the..
Online Published Date:  10 August 2022
Appeared in issue:  296 - 11 July 2022

Professional negligence – Australia

Australia’s commitment to strengthen its anti-money laundering regime by expanding the regulated sector is now an eight-year-old promise that has yet to be fulfilled, but with the change in government this May [2022], there is renewed hope, writes..
Online Published Date:  11 August 2022
Appeared in issue:  296 - 11 July 2022

Professional negligence – Australia

Australia’s commitment to strengthen its anti-money laundering regime by expanding the regulated sector is now an eight-year-old promise that has yet to be fulfilled, but with the change in government this May [2022], there is renewed hope, writes..
Online Published Date:  11 August 2022
Appeared in issue:  297 - 03 October 2022

New dimensions – the Metaverse

Life online is set for a massive step-change, with the creation of spaces and interactivity that will assuredly deliver enhanced opportunities for work and leisure, but also plunder. Keith Nuthall immerses himself in the fresh potentialities for..
Online Published Date:  11 August 2022
Appeared in issue:  296 - 11 July 2022

New dimensions – the Metaverse

Life online is set for a massive step-change, with the creation of spaces and interactivity that will assuredly deliver enhanced opportunities for work and leisure, but also plunder. Keith Nuthall immerses himself in the fresh potentialities for..
Online Published Date:  11 August 2022
Appeared in issue:  297 - 03 October 2022

Smarkets fined UK£630,000 by Gambling Commission for AML and social harm failings

Online betting exchange Smarkets (Malta) Limited has been ordered to pay UK£630,000 (US$741,334) for weak source of funds checks and not identifying and communicating with customers at risk of harm.
Online Published Date:  12 August 2022
Appeared in issue:  296 - 11 July 2022

Smarkets fined UK£630,000 by Gambling Commission for AML and social harm failings

Online betting exchange Smarkets (Malta) Limited has been ordered to pay UK£630,000 (US$741,334) for weak source of funds checks and not identifying and communicating with customers at risk of harm.
Online Published Date:  12 August 2022
Appeared in issue:  297 - 03 October 2022

AML revisited – CDD primacy

Billions spent for minuscule return: is it time to rework the whole approach to anti-money laundering – prioritise customer due diligence, scrap reporting and direct far more resource to law enforcement? Keith Nuthall and Sarah Gibbonsexamine a radical proposal.
Online Published Date:  12 August 2022
Appeared in issue:  296 - 11 July 2022

AML revisited – CDD primacy

Billions spent for minuscule return: is it time to rework the whole approach to anti-money laundering – prioritise customer due diligence, scrap reporting and direct far more resource to law enforcement? Keith Nuthall and Sarah Gibbonsexamine a radical proposal.
Online Published Date:  12 August 2022
Appeared in issue:  297 - 03 October 2022

Nedbank fined R20m in South Africa for sweep of AML flaws

South African deposit-taker Nedbank Limited will pay a R20m (US$1.22m) administrative penalty for wide-ranging breaches of the country’s Financial Intelligence Centre Act 38 of 2001.
Online Published Date:  15 August 2022
Appeared in issue:  296 - 11 July 2022

Nedbank fined R20m in South Africa for sweep of AML flaws

South African deposit-taker Nedbank Limited will pay a R20m (US$1.22m) administrative penalty for wide-ranging breaches of the country’s Financial Intelligence Centre Act 38 of 2001.
Online Published Date:  15 August 2022
Appeared in issue:  297 - 03 October 2022

The good SAR

An intelligence database must be mined to be useful but by whom and why, specifically? Tristram Hicks argues that the investigatory value in suspicious activity reports - all of them - is best extracted by frontline law enforcement to tackle the crime they see.
Online Published Date:  15 August 2022
Appeared in issue:  296 - 11 July 2022

The good SAR

An intelligence database must be mined to be useful but by whom and why, specifically? Tristram Hicks argues that the investigatory value in suspicious activity reports - all of them - is best extracted by frontline law enforcement to tackle the crime they see.
Online Published Date:  15 August 2022
Appeared in issue:  297 - 03 October 2022

Lloyds Bank Corporate Markets fined UK£498,000 in Jersey over correspondent banking risk breach

The Jersey branch of Lloyds Bank Corporate Markets (LBCM) must pay a civil penalty of UK£498,000 for not identifying and properly managing the risk of a correspondent banking relationship between 2008 and 2018.
Online Published Date:  16 August 2022
Appeared in issue:  297 - 03 October 2022

Lloyds Bank Corporate Markets fined UK£498,000 in Jersey over correspondent banking risk breach

The Jersey branch of Lloyds Bank Corporate Markets (LBCM) must pay a civil penalty of UK£498,000 for not identifying and properly managing the risk of a correspondent banking relationship between 2008 and 2018.
Online Published Date:  16 August 2022
Appeared in issue:  296 - 11 July 2022

US Congress to adopt ‘Enablers’ Act in AML and corruption crackdown

The US Congress is gearing up to adopt the ENABLERS Act, which would extend anti-money laundering requirements (AML) in the Bank Secrecy Act, such as customer due diligence and reporting suspicious transactions, to professional service providers, including lawyers and accountants, third-party payment services and people who form or register companies or trusts.
Online Published Date:  19 August 2022
Appeared in issue:  296 - 11 July 2022

US Congress to adopt ‘Enablers’ Act in AML and corruption crackdown

The US Congress is gearing up to adopt the ENABLERS Act, which would extend anti-money laundering requirements (AML) in the Bank Secrecy Act, such as customer due diligence and reporting suspicious transactions, to professional service providers, including lawyers and accountants, third-party payment services and people who form or register companies or trusts.
Online Published Date:  19 August 2022
Appeared in issue:  297 - 03 October 2022

Entain, gambling operator, pays UK£17m for “completely unacceptable” compliance failures

A record UK£17 million (US$20,019,540) fine on Entain Group is the UK Gambling Commission’s response to anti-money laundering and social responsibility failings in both its online and bricks and mortar businesses.
Online Published Date:  19 August 2022
Appeared in issue:  297 - 03 October 2022

Entain, gambling operator, pays UK£17m for “completely unacceptable” compliance failures

A record UK£17 million (US$20,019,540) fine on Entain Group is the UK Gambling Commission’s response to anti-money laundering and social responsibility failings in both its online and bricks and mortar businesses.
Online Published Date:  19 August 2022
Appeared in issue:  296 - 11 July 2022

Cashing in, and out

Timon Molloy (timon.molloy@informa.com), Editor
Online Published Date:  25 August 2022
Appeared in issue:  297 - 03 October 2022

Germany scores moderate (and better) FATF effectiveness outcomes despite major defects

The world’s fourth largest economy is performing inadequately in many areas of anti-money laundering and counter terrorist financing, according to the 2022 mutual evaluation report for Germany, released by the Financial Action Task Force on 25 August.
Online Published Date:  26 August 2022
Appeared in issue:  297 - 03 October 2022

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