When we found an advertisement for illegal downloads of Sun Tzu and the Art of Litigation, we wrote to everyone that public records showed as connected to the issue or hosting of the domain. We found, again, that Cloudflare was at the heart of the illegal operation and therefore being paid to provide services to criminals who may be generating profits for organised crime or for material support for terrorists. FCROs must consider the business practices and risk management models of their customers because, by definition, banks are receiving, harbouring and distributing the proceeds of...
We've come across Cloudflare before. Their standard response is that they are not responsible for any content on their servers. That, Nigel Morris-Cotterill argued in his book Cleaning up the 'Net cannot be right: they are facilitating the commission of a crime and there are plenty of tools available to them to prevent criminals using their platform.
All cloud services providers are in a similar position: AWS, an Amazon.com service, is one of the primary sources of illegal spam. It is not difficult for AWS to identify those users and block the sending of e-mail before any escapes from its perimeter.
We have previously reported the actions of a cloud services provider to the FBI's field office nearest their premises. The FBI did not respond.
While there are increasing reports about how dozens of individuals have been arrested, there appears to be no action taken against large companies that benefit from crimes. However, the companies are benefiting from, at least, fraud and, therefore, there is money laundering.
Financial institutions which provide services to those companies are therefore receiving, harbouring and distributing the proceeds of criminal offences.
It's time that those financial institutions began to look at the business models, and risk management processes, of its clients.
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