World Money Laundering Report

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?

It's incredible. The European Union has produced five Money Laundering Directives and still in some respects it is not one but two steps behind some countries that are often subject to criticism. Indeed, it is behind many of its own member states. This week, the Council of the European Union "adopted" a "regulation." Politically, the fact that a Regulation has been made is more important than what it does.

It's a story that isn't gripping Malaysia: in 2015, a helicopter crash resulted in the deaths of several prominent members of the government of then Prime Minister Najib that Najib's office said was carrying guests from a wedding reception for Najib's daughter. Now, in an action before the Shariah High Court in Kuala Lumpur, there's a dispute over the very substantial estate of one of the politicians. So far, in a country obsessed with 1MBD, no one is asking loudly how such wealth was accumulated by one man in a life in public service.

As reported at https://www.pleasebeinformed.c..., FinCEN can't get its act together over certain beneficial ownership rules.

This really is a story about money laundering. Stay with us: first, it's not at all a done deal that whatever happens in Brexit, UK lawyers will lose out for any reason except sentiment. Yes, long term, international recognition may be more complex but that could well turn out to be to the advantage of English (specifically, but perhaps one or two South Wales firms might be included) lawyers as their gene pool becomes less diluted. But everyone acknowledges that there should be some kind of hedge against that risk and so large firms are putting in place measures to be, in effect, dual citizens (not legally accurate, of course). Now Theresa May, in need of a win, has done something that will both assist UK lawyers and really, really get up the nose of those Eurocrats who are trying to frustrate the will of the UK people. And there's a not-to-well hidden benefit for British businesses outside the legal sector, too.

A doctor prescribed meds his patients didn't need, claimed payment and spent the proceeds. Now he's serving a 12 year jail sentence for, amongst other things, laundering the proceeds of his own offence.

A very suspicious e-mail spoofing email addresses of not one but two banks and appearing to link to a website appearing to relate to an embassy has been received at the offices of The Anti Money Laundering Network. The hook is information on OFAC blacklists. The mail is in HTML format and therefore disguises the destination of links and also enables the placing of in-line graphics. We place regulators, enforcement agencies and those in financial institutions, especially in compliance and risk management, on alert.

Organised by Casino Essentials, a three-day conference and exhibition started in Las Vegas yesterday with the opening Keynote Presentation by Kenneth Blanco, Director, FinCEN. Before he got down to the nitty-gritty yesterday, Blanco was chummy with the lawyers and gaming industry reps and in his remarks prepared in advance he said "Thank you for that wonderful introduction, Jim" and "Thank you so much, Mindy, for inviting FinCEN to be a part of this event." So, chummy and psychic? How did the rest of his speech go? We know...

FinCEN can't make its mind up. On 16 May this year, FinCEN granted to covered financial institutions a 90 day exception from the requirement to comply with the " Beneficial Ownership Rule for Legal Entity Customers." Leaving aside the fact that, as with the UK's draft Bill, the term "Beneficial Owner" has been co-opted from an entirely different area of law and is therefore a cause for confusion, FinCEN Is up to its old tricks of mitigating the effect of a Rule while pretending that the USA has a strong counter-money laundering regime. The 90 days is up and, guess, what? FinCEN has extended it. What is going on?

See Part I

One of the basic principles of UK company law was for generations that there is a public register of the officers of companies and that that register includes the "Usual Residential Address" of directors and secretaries, with that information being maintained, and publicly accessible, for both current and historical data. That was then and this is now.. and surprisingly it's nothing to do with GDPR.

The announcement of a new consultation begs a question: if the register will apply to those who own "land," i.e. real estate, what about those who own property in long leases (i.e. personalty and not land) in the great estates of London which are, after all, some of the most expensive property in the world. WMLR digs into the proposed Bill to investigate this and other issues.

Consultation: https://www.gov.uk/government/...
Announced 23 July 2018 Closes 17 September 2018

A Court has ruled that law firm was not culpable for making payments, from its clients' account, for the benefit of clients who were subject to a freezing order.

While there is global fascination with the case against Malaysia's former prime minister Najib Razak, who has been charged with offences that, at present, do not include money laundering, the world is seeing an unprecedented range of cases brought against politicians and those close to them. Has the tide turned and are politicians, previously considered largely untouchable, now legitimate targets?

There is a wonderful, and completely fictitious, meme going around Malaysia - Najib asks Anwar if he has any advice for being in jail. Anwar answers "don't drop the soap." Aside from being hilarious, in a country where political comment has for some years ended up with people being arrested, there is the irony that Najib is attempting to run the defence that charges against him are politically motivated - exactly the failed defence that put Anwar in jail. Unlike Anwar, Najib is being vocal in denying any wrongdoing which is also ironic because almost no one in the country wanted Anwar charged, much less convicted.