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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
Fallout – de-risking, the unintended consequences
The Financial Action Task Force is worried [1], and so are member governments [2]: de-risking threatens to exclude swathes of business and consumers from banking services. Alan Osborn, in London, and Craig Howie, in Washington DC, examine the impact..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Sanctions listing to lifting
The pariah status of sanctions list designation is prompting targeted parties to fight for removal, with some notable successes in the European Court of Justice. Katherine Buckle of QEB Hollis Whiteman and Lennart Poulsen of 9 Bedford Row examine..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Virtually here – Bitcoin, but the beginning
The virtual currency genie is out of the digital bottle and innovating his way across the internet at a furious pace, but not without cost. Brian Stoeckert of Stratis Advisory reviews the enforcement actions and criminality that have dogged his..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Fourth EU ML Directive adopted after European Parliament vote
The Fourth EU Money Laundering Directive (4MLD) will come into force mid-2017 after a key vote today [20 May] in the European Parliament signalled the legislation’s adoption [1] following EU Council of Ministers approval a month ago [20..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Fourth round – unready reckoning
Evaluation of countries’ AML/CFT regimes stepped up several gears in 2013 with the Financial Action Task Force (FATF) move to gauge effectiveness, not just technical compliance with its standards. First measurements now taken, they reveal..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
SARs extra – alternative reporting channels
Suspicious activity reports to the financial intelligence unit may be the recognised mechanism for alerting law enforcement to potential criminal fund flows but Alan Osborn finds there are other ways to flag concerns.
Not everybody is as..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Catch up Down Under
After a less than glowing evaluation of its AML/CFT regime ten years ago, one might have expected Australia to raise its game significantly but performance remains distinctly lacklustre, according to the latest Financial Action Task Force findings...
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Fast forward – next generation insight
High performance analytics is set to turbo-charge monitoring and detection, and it can work with existing AML tools, says Alexon Bell, Compliance Solution Director, SAS.
Over the past twenty years, financial institutions have had to..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Out on the edge – virtual banks
The provision of financial services outside the traditional sector, always an attractive prospect to some, becomes ever easier online as the necessary software is commoditised. Alan Osborn and Robert Stokes look at the rise and risk of alternative..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Criminal property – definitively defined?
The amorphous boundary between a predicate offence and a money laundering offence has been diligently plotted out in case law since the Proceeds of Crime Act 2002 came into force, but, as David McCluskey and Charlotte Tregunna of Peters & Peters..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
It’s all about Eve, the first money launderer
All was not paradise for long in the Garden of Eden, an ancient account, says Tristram Hicks, that sheds light on why the European Union now faces its Fourth Money Laundering Directive.
It’s all about Eve really; if people agree..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015
Nordea and Handelsbanken fined by Swedish regulator for AML breaches
Sweden’s two largest banks, Nordea and Handelsbanken, have been fined SKr50 million (€5.4 million) and SKr35 million (€3.8 million), respectively, for money laundering control breaches.
The Financial Supervisory Authority said..
Online Published Date:
27 May 2015
Appeared in issue:
224 - 27 May 2015