i-law

Money Laundering Bulletin

Malta FIAU fines five firms over risk assessment, due diligence and monitoring to close 2022

In an end of year sweep, the Maltese Financial Intelligence Analysis Unit (FIAU) published a batch of enforcement notices against two online casinos, a forex and precious metals trading services firm, and a couple of banks. The failings of each follow common threads.
Online Published Date:  03 January 2023
Appeared in issue:  300 - 01 February 2023

Two law firms fined by UK regulator for risk assessment and control failures

A sole practitioner in Leeds and a Bristol-based practice have admitted breaching the UK Money Laundering Regulations 2017 after "proactive AML inspection[s]" by the Solicitors Regulation Authority.
Online Published Date:  07 January 2023
Appeared in issue:  300 - 01 February 2023

GT Bank fined £7.7m in UK for repeat of AML breaches

The UK subsidiary of Nigeria's GT Bank must pay a UK£7,671,800 penalty after the Financial Conduct Authority (FCA) found comprehensive failings under the Money Laundering Regulations across the period 21 October 2014 to 12 July 2019, even though the anti-money laundering (AML) control flaws were previously noted by its own Compliance and Internal Audit functions, an external consultant, and highlighted by the regulator in 2014 and 2017.
Online Published Date:  11 January 2023
Appeared in issue:  300 - 01 February 2023

Al Rayan Bank pays £4m in UK for C/EDD, cash control faults

Al Rayan Bank PLC - Birmingham UK-headquartered subsidiary of Masraf Al Rayan Q.S.C, a Qatar-based Islamic bank, has been fined UK£4,023,600 by the UK Financial Conduct Authority (FCA) for breaching Principle 3 in the area of anti-money laundering risk-sensitive policies and procedures between 1 April 2015 and 30 November 2017.
Online Published Date:  12 January 2023
Appeared in issue:  300 - 01 February 2023

Coinbase fined US$50m in New York for CDD, transaction monitoring & reporting failures; ordered to invest US$50m in AML remediation

Cryptocurrency trading platform Coinbase has been ordered to pay US$50 million for "serious deficiencies" in its Bank Secrecy Act/Anti-Money Laundering compliance around customer due diligence, transaction monitoring, suspicious activity reporting and sanctions screening after an examination by the New York Department of Financial Services, covering 1 July 2018 to 31 December 2019, and a follow-up investigation.
Online Published Date:  15 January 2023
Appeared in issue:  300 - 01 February 2023

Evasive action - Russia v. sanctions

Cryptocurrencies may be used to circumvent western sanctions on Russia even as mining them is still illegal in the country, but then so much is irreconcilable in the conflict pulverising Ukraine. Ekaterina Mereminskaia, Paul Cochrane and Keith Nuthallfind, though, no reason to doubt that the war by economic means is every bit as strategic, and calculated, as the military campaign.
Online Published Date:  16 January 2023
Appeared in issue:  300 - 01 February 2023

Back to the age-old question: who should bear the cost of KYC and KYB checks?

Around Christmas 2022, writes Claus Christensen of Know Your Customer Limited, Dutch clients of business banking services received a piece of news they could probably have done without...
Online Published Date:  20 January 2023
Appeared in issue:  300 - 01 February 2023

The Danske debacle - a case study in failure

After as much as €200 billion in largely suspicious transactions for non-resident customers were processed by the Estonia branch of Danske Bank between 2007 and 2015, there was always going to be a mighty reckoning, and so it came, in December [2022], with criminal and civil penalties in the United States and Denmark. Denis O'Connor studies a chronology of disastrous, protracted non-compliance.
Online Published Date:  20 January 2023
Appeared in issue:  300 - 01 February 2023

Are you ready? - when a regulator calls

Whether a scheduled examination or, worst case, a dawn raid, AML compliance will pay a heavy price if caught unprepared. Paul Cochrane studies eternal vigilance.
Online Published Date:  20 January 2023
Appeared in issue:  300 - 01 February 2023

BNF Bank fined €189,274 in Malta for risk assessment, monitoring, record-keeping breaches

An offsite review by Malta's Financial Intelligence Analysis Unit, in 2020, of BNF Bank Plc found failings in its anti-money laundering controls that have resulted in a €189,274 penalty, a reprimand and instruction to correct the faults.
Online Published Date:  23 January 2023
Appeared in issue:  300 - 01 February 2023

USA 'gatekeeper' AML bill stalled in Senate

A planned expansion of US anti-money laundering (AML) laws to cover so-called 'gate-keeper professions', including company service providers and lawyers, has been halted by the US Senate, which refused to write the law into the 2023 annual defence appropriations law.
Online Published Date:  24 January 2023
Appeared in issue:  300 - 01 February 2023

Major rise in SARs volume and suspect funds locked - UK FIU report

The latest SARs Annual Report from the UK Financial Intelligence Unit (UKFIU), in the National Crime Agency, covers 2020-21 and 2021-22, so both the Covid-19 pandemic and implementation of sanctions following Russia's invasion of Ukraine, which, says Jonathan Grimes of Kingsley Napley, may help explain the 21% increase in suspicious activity reports, to 901,255, received in the year ending 31 March 2022.
Online Published Date:  25 January 2023
Appeared in issue:  300 - 01 February 2023

EU adds Gibraltar to high-risk list for money laundering

The European Commission has added the British overseas territory of Gibraltar to the European Union (EU) list of high-risk countries with strategic deficiencies in their anti-money laundering and countering the financing of terrorism regimes.
Online Published Date:  25 January 2023
Appeared in issue:  300 - 01 February 2023

In Touch Games, TonyBet and Vivaro fined for AML breaches by UK gambling regulator

Three online gaming operators collected fines in January from the UK Gambling Commission for anti-money laundering control failings.
Online Published Date:  26 January 2023
Appeared in issue:  300 - 01 February 2023

What makes an AML Expert?

It must have been sometime around 2010 when I received a phone call from a recruitment agency telling me they urgently needed an AML SME, remembers Mario Menz.. Nowadays most of us know SME - at least when those three letters are placed after AML - means "subject matter expert". But back in 2010, working in a corporate banking environment, SME to me meant small and medium-sized enterprise. Why, I thought at the time, would anyone urgently need a small or medium-sized enterprise for AML purposes?
Online Published Date:  30 January 2023
Appeared in issue:  300 - 01 February 2023

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