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World Money Laundering Report

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.

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**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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The UK's Financial Conduct Authority has revealed that, in 2017, it secured the conviction for money laundering of one Richard Baldwin. However, the case was kept out of the public eye due to reporting restrictions.

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"It was the computer wot done it, guv," is the latest excuse to come out of a major bank caught with its money laundering knickers around its ankles.

There's just one incy-wincy-little point. It wasn't the software - it was the people .. and it's the same problem that makes reliance on so-called AI so dangerous, Nigel Morris-Cotterill says.

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It has become fashionable to talk of "The Three Lines of Defence" in relation to money laundering, terrorist financing, etc. Is it just more more quasi-militaristic buzzwords, so loved by Americans, and a pretence of intellect or is there genuine merit here?

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The responsible officer of a securities brokerage has been banned from the industry for ten months as a result of his "failure to discharge his duties as an RO" and a member of the company's senior management. The company has been fined a substantial amount, too.

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