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World Money Laundering Report

This week, Nigerian President Muhammadu Buhari has signed three Bills, bring them into law. Bucking the global trend to try to incorporate multiple aspects of financial crime law into a single piece of legislation, the new Acts are the Money Laundering (Prevention and Prohibition) Act, 2022, the Terrorism (Prevention and Prohibition) Act, 2022, and the Proceeds of Crime (Recovery and Management) Act, 2022. But the word of the day is "irony."

Those with long memories will remember the well-worn name of Andre Coker. It's been used in a variety of spam-scams but, at least insofar as it's reached us, been unused for some time. But it's back and Andre is a woman now.

Recently, there has been renewed interest in the question as to whether an FIU should ask reporting entities to pre-qualify reports so that the FIU receives only "quality" reports. Here's the view of Nigel Morris-Cotterill

AUSTRAC, Australia's combined FIU and regulator, yesterday issued civil (not criminal) proceedings against Crown alleging "serious and systemic non-compliance."

The action is against Crown Resources in both Sydney and Melbourne. The allegations are that, despite previous action and warnings, Crown remains short of the minimum standards that AUSTRAC requires.

Luke Raven provides an accessible and clearly set out explanation of the issues surrounding the imposition and effect of financial sanctions.

Whatever happened to "nice"?

Canadian Prime Minister Justin Trudeau has said that he will use provisions in The Emergencies Act to freeze the accounts of those taking part in protects against compulsory vaccination.

From "nice" to "nuclear" in one step because the power is extraordinary in every sense of the word.

It's been a long time coming - a major bank is subject to criminal prosecution in its home jurisdiction for money laundering.

Or so the hundreds, if not thousands, of headlines say.

But the attention is misplaced because the bank is not charged with money laundering, but - as has happened so often in the past - a money laundering related offence.

India's Enforcement Directorate has frozen assets of a property company and associated individuals worth approximately 4,100,000,000 Rupees (just over GBP40 million /USD55 million) arising from allegations of fraudulent loan applications and subsequent money laundering.

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.

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