The school of hard cash

Should EU money laundering legislation extend to cover cash payments of €15,000 or more for services? The lesson from the education sector is instructive, says Sue Grossey.

Susan Grossey may be contacted on +44 (0)1223 563636, susan@thinkingaboutcrime.com, www.thinkingaboutcrime.com In response to an increasing number of requests for AML training for non-executive directors (NEDs), Sue has written “Anti-Money Laundering: A Guide for the Non-Executive Director”, in four separate editions – for Guernsey, Jersey, the Isle of Man and the UK. Every director must be aware of the heightened requirements of the AML/CFT regime of his jurisdiction, and of his specific responsibilities under the four tenets of that regime: customer due diligence, record-keeping, internal reporting, and staff training. This book presents that information in a concise and palatable format, with key questions guiding the NED’s understanding of each section. For further information visit www.thinkingaboutcrime.com/publications.htm

As we prepare ourselves for an update to the Third European Money Laundering Directive, you might like to think back to the arrival of that directive. It was a few years ago now, but one of the matters under discussion at the time was the extension of the regulated sector – by which I mean those businesses covered by whatever anti-money laundering regulations are in place in the jurisdiction. There was much horse-trading and protracted negotiation among the member states, in particular with regard to the definition of “High Value Dealers”. As you all know, these are now those who accept cash payments of €15,000 or more in exchange for goods – but at one point it looked as though the category might also include those who accept cash payment for services. Had they been included, we would have had all sorts of interesting new entrants to the regulated sector: consultants of all stripes, private clinics and spas, and all manner of educational establishments.