Money Laundering Bulletin
Careless whispers?
Denis O’Connor, a Fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment, was a member of the British Bankers’ Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group’s Board and Editorial Panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the UK and abroad.

JP Morgan’s Global Head of Escrow wrote to his Global Head of Financial Crime Compliance that “the structure of the… escrow
didn’t make sense in light of the underlying transaction”, “we did not know the final beneficiaries… until we were asked to
make the final payment” and “[T]his was a miss on FGN [Federal Government of Nigeria]”, it has emerged in the latest decision
in ongoing litigation between the Federal Republic of Nigeria and the bank over recovery of US$875 million (plus interest
and costs) which the African state claims was linked to a corrupt oil deal.
Denis O’Connor discovers dilemma in the disclosures.