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FinancialCrimeRiskOfficers.com

The single over-riding principle that makes cryptocurrency accounts attractive to criminals is not the supposed anonymity (that argument is a done deal except for those who don't know what they are talking about) but the fact that, by design, there is, literally, no single body or person with regulatory authority.

What that means is that, while governments and courts (at the behest of victims) can make Asset Recovery Orders, or, as the US government is trying to do with its listing on OFAC of crypto-currency accounts that it claims it has reasonably identified as connected to listed persons, these are after the fact restrictions and to try to enforce them is, by reason of the essence of the distributed ledger, only ad hoc.

There is another way....

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We've introduced this same spam-scammer over the past few days and it's still at it. This time, however, there's no doubt what it's up to: it's trying to sell fixed return investments without any of the statutory information that's required for such promotions. But,then again, why bother complying with financial sector laws when the whole enterprise shows the signs of being fundamentally illegal?

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Somewhere, a new spam-scam factory is pumping out new schemes at the rate of one every couple of days.

They introduce via a domain name that has nothing to do with whatever they are using as the hook for the scam, but they do have certain things in common which enable us to identify them as sourced by the same spam-scam crew. Today's is from philstudio.net under the banner "Portfolio Direct" and is headed "Free guide to direct lending."

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As low-cost mortgage schemes and Pump and Dump scams return to the internet, there's more proof that frauds are cyclical. Today sees the gold spam we've seen in a while. And it even offers a "standby letter of credit."

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A director entered into an agreement to bribe someone into making sure the company was awarded a contract worth GBP6 million, approx. A new CEO found out, prevented payments, filed a suspicious activity report, asked the police to investigate. Then it all got complicated ...

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HM would not be amused. The UK Treasury, which is increasingly given to adopting American terminology, recently issued an "advisory" relating to jurisdictions with deficiencies in their counter-money laundering and anti-terrorist financing regimes. Hilariously, it was identified as a possible scam by the Thunderbird e-mail client.

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Wherever you are in the world, the so-called Nigerian Scam is alive and well and yesterday's notice from the USA's Internal Revenue Service is the release that will launch a thousand scams - and probably many, many more. It's so serious that the subject line in the e-mail from the IRS raised spam / scam alerts in the Vortex Centrum monitoring system, which can't be good.

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The website for FxUnited (FxUnitedGlobal.com) optimistically says "copyright 2006 to 2020." On its website, it links to a company registration certificate which shows that the company, United Global Holdings Limited was registered in New Zealand under number 5247841 in 2014 and has, since, been removed. But all is not as it seems and the investigation into the huge scam in Malaysia is only one aspect of this case as our own investigations reveal.

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Courts have long had the power to make Orders in relation to assets, usually to prevent their disposal and/or destruction. They are known by a variety of names, and sometimes names mean different things in different jurisdictions.

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The British government has announced the introduction of software to "detect terrorist content" on "any online platform." According to a statement issued yesterday "Tests have shown this new tool can automatically detect 94% of Da'esh propaganda with 99.995% accuracy. " That's amazing - and one has to ask how such figures can be quantified and proved. But there is good news: while large platforms have developed their own tech, smaller companies will be able to use that developed by the British government and ASI Data Science.

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A very funny story in today's South China Morning Post reminds me of the many hilarious tales of my Hong Kong Police mates about vice raids. The anonymous tourist who bemoans his fate in the article is an example of what happens if you think that being a foreigner absolves you from the important action of switching on your brain and learning at least something about what you are getting yourself into, says Nigel Morris-Cotterill

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The biggest corporate news in South Africa at present is that of State owned Eskom where every epithet relating to being rotten can be applied: one rotten apple spoils the barrel, rotten to the core, fish rots from the head.. but, as South Africa's deputy President under Jacob Zuma and the recently appointed head of the African National Congress (a national political party, not a continent-wide initiative) said in an electrifying speech at Davos yesterday, things have to change.

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The sentencing to three years of those involved in a case involving bank loans to a company that then defaulted gives some indication as to why Vijay Mallya is so reluctant to return to India from his UK hideaway.

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A spotlight is being shone onto the world's aircraft manufacturers. Ever since the UK's then Prime Minister, Tony Blair, personally intervened to stop a serious fraud office investigation into payments allegedly made to persons in Saudi Arabia by BAe, the entire industry, from planes to engines to components, is increasingly subject to question. A recent deal between a former executive in a manufacturer and US prosecutors shows the complexity of arrangements intended to obscure corrupt payments and the need for vigilance by financial institutions.

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** access to this document is free **

14 December 2017

A further 100 alleged contraventions against the Commonwealth Bank of Australia (CBA) have been filed today by AUSTRAC, the Government’s financial intelligence and regulatory body, adding to the current civil penalty proceedings.

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