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World Money Laundering Report

US TV carrier Dish Networks is popular for its service and incredibly unpopular for its business practices. US States have been putting the company under pressure for a decade and still it fails and ends up paying whacking fines. At the heart of its problems are these issues: collection, validation and use of internally generated data, use of externally generated data, balancing commercial needs with regulatory demands, all things that are the daily diet of Financial Crime Risk Officers in financial institutions and other businesses affected by money laundering, terrorist financing and bribery/corruption issues.

Nigel Morris-Cotterill suggests that banks and others who terminate e.g. correspondent banking relationships and customers' accounts saying it's because of de-risking might have another option: mentor them to get it right.

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Nigel Morris-Cotterill is one of the world's most experienced counter-money laundering strategists. www.countermoneylaundering.com.
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Every so often, Bitcoin hits the news because a criminal gang is using it for some nefarious purpose. We examined BitCoin in a special issue (see here) in 2013. It was not our first look at virtual currencies: that was way back in the mid 1990s, before we even launched World Money Laundering Report, and we've kept a watching brief ever since. Here's the current scary stuff.

Long long ago, there was a phrase circulating among money laundering investigators that in every money laundering scheme, there is a lawyer. The Financial Conduct Authority, in an action in the Central Criminal Court, has proved that you can't run a property fraud unless someone is doing the paperwork and, in the UK, that's likely to be a solicitor.

We have identified illegal copies of World Money Laundering Report publicised on YouTube, a Google / Alphabet company via a link to a domain difa.us which is registered behind an anonymous e-mail account. When we looked further into the circumstances we found illegal copies of the works of a number of other publishers of professional material including Lexis-Nexis posted under several apparent aliases.

For decades we have been told that we should address everyone by their Christian or first name, even if we have never met. In the past ten years or so, we have been subjected to the constant diminishing of the term "Friend." It's time to stop this and to return to a world where there are boundaries and where everyone knows where they are. And more, it's time to return to formality in business correspondence and, most importantly, to start to show respect for each other instead of a presumption of homogenisation. Why? Because we need healthy scepticism not blind acceptance of everyone and everything.

Yesterday, the USA named several people under the OFAC Specially Designated Nationsls "SDN" list. They are all PEPs in Venezuala so they have gone from "be careful with.." to "don't touch."

One might imagine that, in a post-11 September 2001 world, The Americas would be the worst place that anyone could use an aircraft for illegal purposes. But it's not so. The skies remain friendly to drug dealers for whom aircraft are a tool of choice.

Just how much money can a group of tourists hide in their socks and knickers, plus a variety of other methods of concealment? It's far more than you might think.

Continuing our analysis of AFP v Ganesh Kalimuthu & Anor

For part one see here

The case is said to be on its own facts but the Court was not invited to consider all the relevant facts. It is therefore a narrow judgment. It is a precedent but it is not a comprehensive precedent and creates an open door for international transfers of large amounts of money with impunity.

The facts of the case of Commissioner AFP v Ganesh Kalimuthu & Anor [2017] WASC 108 are superficially simple but that simplicity belies a state of affairs that is not at all straightforward. It involves cross-border payments, the use of an unlicensed money transmitter thinking him to be licensed but which turned out to be a hawala-style transaction of the sort that criminal gangs developed in the Philippines to facilitate expatriation of proceeds of illegal gambling. Now someone has given it a name - the especially stupid name of "cuckoo smurfing." The AFP made a logical decision to freeze moneys but the logic has been defeated by the Court. WMLR looks at the case which, at least in part, is a reflection of the dreadful drafting of Australia's Proceeds of Crime Act 2002.

In 2008, the USA removed North Korea from its list of State Sponsors of Terrorism. But as relations between KIM Jong Un and the rest of the world reach worrying levels of tension, the USA is getting ever closer to putting it back on the list. What does it mean and why are Malaysian banks exposed to a particularly high level of risk?

We all know politics is a dirty business and we all know that fake news seems to be more prevalent than real news.

But, even so..... This is the most amazing story, a) if it's a real story and b) if the allegations are true.

Yesterday, Theresa May, the UK's Prime Minister, took pretty much everyone by surprise by announcing that she was calling a "snap election." This means that, today, Parliament will vote for its own dissolution (not, of course, abolition - the two are entirely different) and that this Parliament will end on 3rd May, assuming a two-thirds majority vote in favour. After that date, no parliamentary business, which includes passing of primary and secondary legislation, can occur until the new session. Amongst the measures affected are those relating to EU driven counter-money laundering law and regulation, unless a massively truncated system can, in some way, be applied. Nigel Morris-Cotterill takes us into the world of Washing Up and the importance of lost debate.

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