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World Money Laundering Report

In what might just count as the simplest money laundering scheme ever, a senior officer of a US bank is to be banged up for two years.

In the past day or so, a company called emailmovers limited using the domain xmr3.com have sent out a number of spam e-mails addressed to personal e-mail addresses at companies. They claim "Emailmovers is one of the UK's only B2B email data owners who provide Full Email Marketing services in house" which is, in itself a nonsensical statement.

But it's their claim for how many people they feel it's OK to send unwanted commercial email to that is interesting. Just how did they get it and how do they think it's legal to use it? And is it a predicate crime for money laundering purposes if they have breached GDPR?

The increased emphasis on the true owners of companies opens up a can of worms. The lid has been loose for years but no one dared take a proper look inside. Now's the time to find out what's buried in that wriggling mass.

"Cognitive bias" is one of those expressions, along with various other forms of bias, that's become popular in recent months. However, there's nothing new and nothing clever about cognitive bias. In fact, it's one of the most fundamental aspects of decision making. We all, without exception, do it. But the problem is that it underpins one of the reasons that financial crime risk management fails, over and over again.

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A lawyer has pleaded guilty to using his clients' account to launder the proceeds of a range of financial crimes in which he also took part. The case shows why Regulations limiting suspicious reporting requirements to "transactional lawyers" are a mistake.

The supposed anonymity of crypto-asset accounts, such as bitcoin wallets, depends on two things: first, the creation of accounts attached to fictitious or false identification information and the fact that there are so many that trying to identify one being used for criminal purposes is like trying to decide which drop in the ocean should be looked at first.

Today, World Money Laundering Report, part of The Anti Money Laundering Network announces the GlobalKYC Suspicious Crypto Asset Register, a crowd-sourced method of identifying those accounts that may be used by criminals for reasons of extortion.

It would be far more sensible if the UK scrapped its money laundering laws, wrote something comprehensible and properly structured and kept it all in one place. But no, that would make life far too simple. So, we have the latest Act that has to be read in the light of, and which makes amendments to, other legislation. But it's important and so no one can simply say "stuff it" and delete it. As it comes into force, there is a hint as to at least some of the priorities in relation to international financial crime.

Yesterday, Singapore passed its Serious Crimes and Counter-Terrorism (Miscellaneous Amendments" Bill. The Lion City's approach to suspicious assets has logic on its side, but it doesn't work in practice. Here is WMLR's analysis of the relevant parts of the Act and its consequences, including risk for compliance / risk officers.

"She was the sort of woman that, if she told you do do something, you did it," PC Robert Carter is reported to have said when asked why he helped his mother, Tamara Carter, to launder the proceeds of criminal conduct from which she received some GBP850,000. A finding of Gross Misconduct at a disciplinary hearing, plus his mother's conviction, suggest that the constable might shortly be receiving a visit from his former colleagues, perhaps even before the Metropolitan Police decide on his penalty. There's an interesting facet to the Board's decision.

Malaysia is being ever so nice to US headquartered bank Goldman Sachs which, through its Singapore Office, it is now known from the evidence given by one of its former staff, Tim Leissner, to have assisted in the theft and laundering of part of the now infamous 1MDB fund.

The bank, which is now seeking to take on new staff in the relevant department in Singapore, has been asked to give back the estimated USD600 million in fees it took for its assistance. Iit's at least arguable that Malaysia doesn't have to ask nicely: it could just take the money. GS doesn't want to pay out in every direction: it's already accepted the probability of "significant fines" in the US as a result of an investigation there.

Here's a step-by-step guide to getting the money back without the bank's co-operation.

The European Bank for Reconstruction and Development has invited expressions of interest for consulting services for financial institutions in Kyrgyz Republic and Tajikistan. Some of the so-called "partner financial institutions," which in the real world would be called "customers" have, the EBRD says, asked for assistance "to conduct a diagnostics (sic) of their internal audit function and provide them with recommendation to strengthen this area in line with the international best practices."

As the request unfolds it becomes, increasingly, a reason for serious head-shaking.

Recent action in Malaysia is making it clear: cash exceeding relatively small amounts is unwelcome. It's not

A notice, relating to the findings of the Financial Action Task Force relating to deficiencies in the counter-money laundering / anti-terrorist financing regimes of several jurisdictions, has been issued by the USA's Financial Crimes Enforcement Network, FinCEN.

The position relating to PEPs has always been complex but Unexplained Wealth Orders are about to take that complexity to a level previously unthought of.

Financial crime risk management - be it related to money laundering, terrorist financing, fraud or embezzlement purposes, to say nothing of anti-bribery requirements - is expensive. For small businesses, it's cost prohibitive. Compliance is even worse. Is it feasible, permissible, even advisable to share the burden with others?

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