Money Laundering Bulletin
Quirks & queries – UK firm risk perceptions
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.

Seventy firms regulated in the United Kingdom believe the country is a “high risk” financial crime jurisdiction according
to the UK Financial Conduct Authority’s recently published summary of 5,685 Financial Crime Reports submitted by around 2,300
firms over a three-year period. [1] Close analysis reveals a number of very unusual responses, says
Denis O’Connor, which may, in turn, call into question the risk-based approach adopted by some firms.