The phrase “money laundering” elicits a frisson of excitement: images of gambling houses, crooked banks and even more crooked employees spring into one’s mind. However, the details provided in Money Laundering Law remind the reader of the careful organization required by the criminal and his accomplices to clean “dirty” money without detection. For the criminal, it is vital to be one step ahead of the law. The Money Laundering Regulations 1993 turned banks and other financial institutions into detectives, requiring identification procedures to be established to check up on new customers and a monitoring system to be put in place to ensure that large unexplained payments are reported to the police. Criminals can meet these legislative challenges in various ways: a process known as “smurfing” can be used whereby accomplices are employed to deposit small sums at various branches of high street banks; alternatively, the scrutiny of respectable financial institutions can be avoided by purchasing a bank or bureau de change in an offshore jurisdiction as a ready deposit for ill-gotten gains. The reader does gain some sense of this “cat and mouse” game which is being played out between the Government and the criminal fraternity, but a greater emphasis on the dynamics of this relationship might have been desirable.

Although the opening chapters (called “divisions”) are largely descriptive in sketching the process of laundering and the legislative background, the scale and complexity of the problems posed by money laundering are clearly delineated. Government legislative measures in response affect not only banks and financial institutions in general but also professionals in other fields. Solicitors and accountants can be asked for help and advice in transferring funds or purchasing commercial property by dishonest clients. Therefore, the careful analysis of the wording of specific criminal offences created by recent legislation (notably the Drug Trafficking Act 1994 and the amendments made to the Criminal Justice Act 1988 by the Criminal Justice Act 1993) is a particular strength of this work.

This work is rather weaker in its treatment of the civil law. Concepts of knowledge and suspicion are discussed as each specific offence is considered in turn. The first offence discussed is the one created by s. 93A of the Criminal Justice Act 1988, as amended. This section imposes criminal liability upon an accessory who is involved in an arrangement which he or she knows or suspects is designed to facilitate the investment of the proceeds of crime or its retention, control or disposition by the criminal. In determining what the accessory knows, is it sufficient for the prosecution to show that he or she should have been put on enquiry? This issue is rightly dealt with in the context of the mirror image cases in the civil law which concern personal liability where there