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World Money Laundering Report

Waheed Zaman explains that the fall of Afghanistan to the Taliban has widespread implications for money laundering and a range of other financial crimes.

This piece was written on 22 August 2021, almost immediately after the fall of Kabul.

More than 100 people put more than USD10 million dollars into, amongst other things, a fake food business. That's a lot of money on average so we can assume these were not stupid people. George S. Blankenbaker Jr., 56 found a honey hole and worked it hard. His reward is jail.

That's not the end of the story...

OFAC has long restricted dealings by US citizens - and others that it can claim jurisdiction over - in relation to ships and aircraft. These are usually in support of some other sanctions. There's no point in applying sanctions to an airline if the aircraft aren't owned by the airline so they can just continue under a new name. So individual aircraft as sanctioned which means it's next to impossible to operate at any airport and to pay for bunkering supplies.

A former Department of Defence civilian official has pleaded guilty to two felony charges for taking tens of thousands of dollars in illegal cash payments from a private contractor to support the contractor’s effort to obtain USD6.4 million from the government in connection with construction projects on a Navy base in the African nation of Djibouti, the US Department of Justice said, announcing a plea of guilty.

The Securities and Exchange Commission has issued civil proceedings against Matthew J. Skinner of Santa Clarita, California and five entities he owns and controls – Empire West Equity Inc., Bayside Equity LP, Longacre Estates LP, Freedom Equity Fund LLC, and Simple Growth LLC – for conducting four unregistered and fraudulent real estate investment offerings between 2015 and 2020, through which, it is alleged, he raised more than USD9 million from over 100 investors.

There's a caveat to this article: it's not a financial crime Bill but it has a serious financial crime impact.

The Financial Crimes Enforcement Network (FinCEN), jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency, and in consultation with the staff of certain other federal functional regulators, has issued responses to Frequently Asked Questions (FAQs) Regarding Suspicious Activity Reporting and Other Anti-Money Laundering (AML) Requirements.

Summary below.

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.

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