- Home/Publications/Money Laundering Bulletin
                                            
                                                Bank Hapoalim agrees US$874m settlement for US tax evasion conspiracy, pays US$30m for laundering role in FIFA bribery scheme
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Bank Hapoalim B.M. (BHBM), Israel’s largest deposit-taker, and its Swiss subsidiary (BHS), will pay US$874.26m to US authorities for helping US taxpayers set up secret accounts to conceal assets and income offshore. [1]BHS pled guilty, while..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        01 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day thirty-nine
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        01 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day forty-two
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        04 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day forty-three
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        05 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                EU expands high ML risk third country blacklist – leaked draft
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The EU list of third countries designated high risk over failures to address money laundering and terrorist financing is set to lengthen from 16 to 22, but excludes some states previously featured then removed after political intervention, according..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        06 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day forty-four
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        06 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                EU plans AML/CFT law by regulation and single supervisor
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    By Keith Nuthall
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        07 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day forty-five
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        07 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                EU updates high ML risk third country list
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The European Commission issued, on 7 May [2020], a revised list of third countries that it considers have “strategic deficiencies” in their anti-money laundering and countering terrorist financing regimes. [1]Under a new methodology, applied after..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        08 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day forty-nine
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        11 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        12 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty-one
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        13 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty-two
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        14 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                EU AML action plan short a police force, says MEP
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    BySara Lewis, in Brussels
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        14 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown – day fifty-three
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        15 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty-six
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        18 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Southwest Securities (HK) Brokerage Ltd fined HK$5m over third party deposit control breaches
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The Hong Kong Securities and Futures Commission has ordered Southwest Securities (HK) Brokerage Ltd (SSBL) to pay HK$5 million after it discovered failings in controls over third party deposits (TPDs) into client accounts, as well as monitoring and..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        19 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty-seven
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        19 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty-eight
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        20 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                European Commission cracks down on ML Directive transposition flaws and delays
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    By Sara Lewis, in Brussels
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        21 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day fifty-nine
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        21 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day sixty
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        22 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day sixty-four
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        26 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Pilatus Bank fined €10,000 for not assisting FIU
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    PilatusBank, now in administration, was fined €10,000in December [2019], over failure to respond to two information requests by Malta’sFinancial Intelligence Analysis Unit.The disclosure to parliament, by Lawrence Connell, the bank’sadministrator,..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        26 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Fraudulent trading risks in insolvency and corporate restructuring cases
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Jonathan Fisher QC (jf@brightlinelaw.co.uk) is Lead Counsel at Bright Line Law (https://brightlinelaw.co.uk/)
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day sixty-five
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                A walk on the wild side
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Susan Grossey may be contacted on +44 (0)1223 563636, susan@thinkingaboutcrime.com, www.thinkingaboutcrime.com
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Trading partners (in crime)
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The vast majority of commercial tradesare settled by the buyer transferring the purchase cost sum from his or herbusiness bank account to that of the seller. Who is to say, though, if theprice is right or deliberately misstated to effect laundering?..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Less is more – towards a lower rate of false positives
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Alexon Bellis Chief Product Officer (Anti-Money Laundering) at Quantexa (www.quantexa.com).
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Tech traps – AML hacked
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    The buzz around regtech and artificialintelligence has not gone unnoticed by those whose livelihoods are threatened: KeithNuthall, Barbara Bierach and Paul Cochrane find the black hatsare working equally hard to compromise the new defences to ensure..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Learning points – an international AML education survey
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Anti-money laundering may, increasingly, offer a clear career path, but the attendant training and qualification structure is inchoate, with doubts, finds Keith Nuthall, that it will ever coalesce into a formal, let alone global structure.En..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Steep ascent – Nepal
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    
                                                    Themountainous kingdom of Nepal faced a long trek from base camp after anavalanche of criticism heaped on its anti-money laundering efforts by the AsiaPacific Group in 2011. A decade on and the APG is returning to check onpreparations for another..
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        27 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day sixty-six
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        28 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                Cross-border information-sharing – insubstantial guidance for UK corporates
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Josef Rybacki (+44 (0)20 7872 1517, josef.rybacki@wilmerhale.com) is an associate in WilmerHale’s UK White Collar Defence and Investigations team.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        28 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020
                                                    
                                                
                                            
                                            
                                                US charges 32 with complex scheme to fund North Korea’s nuclear weapons programme
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    By Keith Nuthall
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        29 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            275 - 01 July 2020
                                                    
                                                
                                            
                                            
                                                UK lockdown - day sixty-seven
                                            
                                            
                                                
                                        
                                    
                                                
                                                    
                                                    Martin Woods (martin@amlwoods.com) is a former Metropolitan Police Officer and latterly the Head of Financial Crime at Thomson Reuters.
                                                    
                                                
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                                    Online Published Date: 
                                                    
                                                        29 May 2020
                                                    
                                                
                                                
                                                    Appeared in issue: 
                                                    
                                                            274 - 01 June 2020