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World Money Laundering Report

Boylesports Enterprise has been found to have breached Gambling Commission rules aimed at preventing money laundering on its websites Boylesports.com and Boylecasino.com .

Sarah Beth Felix of Palmera Consulting, considers whether The FinCEN Files are a help or a hindrance when it comes to trying to engage both the public and senior management with the challenges facing Financial Crime Risk and Compliance Officers.

Yesterday, the USA's Financial Crimes Enforcement Network (FinCEN) today issued an Advance Notice of Proposed Rulemaking(ANPRM) to solicit public comment on a wide range of questions pertaining to potential regulatory amendments under the Bank Secrecy Act.

The Financial Crimes Enforcement Network, the USA's Financial Intelligence Unit and money laundering, etc., regulator, has today issued a statement on the enforcement of the Bank Secrecy Act.

The full statement (slightly edited for form, not edited for content) is below.

The USA's Financial Crimes Enforcement Network (is that horrible logo new? FinCEN used to be so elegant) has issued a civil money penalty notice against a former Chief Officer of U.S. Bancorp N.A. for "failure to prevent" breaches of the Bank Secrecy Act during his employment at the company. But, FinCEN's allegations go further than simply "failing to prevent."

The Financial Action Task Force has removed Trinidad and Tobago from its list of countries subject to "enhanced monitoring."

But there are eighteen still on the list including one, in particular, which has been mounting a charm offensive.

This is a fascinating idea: if a financial services business operates in "more than three" EU member states, its regulators will create a "college" so as to make sure that it's not using regulatory arbitrage between member states.

Just one point: is this a recognition that the EU has failed to impose and enforce pan-European Regulation?

OK, there are lots more than one point.

On 30 August 2019, the Regional Trial Court (RTC) in Manila granted the Anti-Money Laundering Council’s (AMLC) Petition for Civil Forfeiture of over PhP23 million (approx 410,700 euros), which stemmed from the proceeds of drug trafficking.

There is a raft of cases around the world involving money seemingly of Chinese origin. Here's a Q&A on the issue.

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The fintech world is at last waking up to the biggest problem facing real-world businesses: how to perform KYC on customers you will never physically meet and who live lives which do not intersect with your own except for one specific purpose - the provision of a service. Of course, being tech-driven, fintechs are looking for a tech solution and they've even got a name for it - Digital Identities. The world is full of "White Papers" but there are no practical applications nearing real-world testing, so far as we can ascertain. It appears that, as in so many cases, people are starting with the tech and trying to make the problem fit it, rather than looking at the problem and trying to build tech around reality, says Nigel Morris-Cotterill.

Long read. Free for seven days.

**This article has been updated for spelling, grammar and one or two additions or amendments performed to improve clarity.** 11 November 2019.

It was as bank called Republic and it came up for sale. It had a lot of Russian business and quite a lot involving Iran and the super-rich before it was normal to be suspicious of the super-rich who had made their money out of the public eye. It was December 1999 and Edward Safra, the owner of Republic (he described himself as Chairman but he was almost the only significant decision maker) was found in his flat in Monaco. During a fire, he had locked himself in a bathroom and died of smoke inhalation in a bathroom with a nurse. He had shot himself. Twice. Or one of his nurses set the fire, depending on which version of events one believes. Whatever, the deal to sell Republic to Bank of New York went ahead and mayhem ensued. Now there's a new chapter to the story.

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The USA's financial crime regulator and FIU, the Financial Crimes Enforcement Network, FinCEN, has announced that it has "launched" the "Global Investigations Division" or (inevitably) "GID". It is being sold as being focussed on money laundering threats that originate abroad. But what is it really? And has FinCEN at last found its calling?

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Criminals and others who act against the interests of society at large are almost always ahead of financial crime and other risk managers when it comes to the the planning and execution of activity. Criminal and anti-social activity are magnified in relation to the effect on economies, even ultimately being an accelerant in the fires that led to the global financial crisis that only the most naive or self-centred deny is over. The fascinating thing is this: while they don't know it, the seeds of major, even pandemic, crime are easily visible. You just need to know where to look.

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