Featured Articles

Precious Metals: A Money Laundering Magnet

While covertly operating within the underworld as a money launderer, I had the occasion to deal with some of the most notorious money launderers in the world. I’ll never forget a particular steamy evening in Panama when I was having dinner with an old friend of Panamanian General Manuel Noriega. Read More

Refereeing Football: The EU’s Yellow Card for Money Laundering

Professional football clubs and players’ agents will be required to report suspicious transactions to the police or face criminal sanctions, just like banks, if radical measures proposed by the European Commission are adopted. These measures are recommended in the Staff Working Document that accompanied the Commission’s recently published Supranational Risk… Read More

Rooting for OFAC: A Sanctions Compliance To-Don’t List

In guidance published earlier this year (“Framework document”), the US Treasury Department’s Office of Foreign Assets Control (OFAC) lists 10 “root causes” of inadequate sanctions compliance programs (SCPs) derived from historical enforcement actions it has taken: Lack of a formal OFAC SCP Misinterpreting, or failing to understand the applicability… Read More
By Naomi Roht-Arriaza, University of California, Hastings Guatemala’s next leader will be Alejandro Giammattei, a right-wing former national prison director. With 58% of votes, Giammettei beat former first lady Sandra Torres by 16 points in the second round of Guatemala’s election on Aug. 11. It was his… Read More
The UK’s HM Treasury recently (and belatedly) published its Anti-Money Laundering and Counterterrorist Financing Supervision Report for the year ended 31 March 2018. With publication of the findings coming some fifteen months after the end of the review period, regulators and supervisors have no excuses for failing to address the… Read More
By Charles Livingstone, Monash University Regulatory failure has been a hot topic in Australia recently. Royal commissions into the financial and aged care sectors have revealed major regulatory failures. The harm done by these oversights has been significant. Regulation is not just red tape. It protects… Read More
By Ofer Raban, University of Oregon The scope of financial crimes unearthed so far by state and federal authorities investigating President Trump and his associates is remarkable. Paul Manafort was found guilty of bank and tax fraud, and faces another trial involving charges of money laundering. Former… Read More
A recent update to the US Justice Department’s guidance on assessing corporate compliance programmes is intended to help federal prosecutors determine when to pursue criminal indictments or prosecution agreements with companies, but that shouldn’t deter compliance professionals from reviewing the document. There are lessons within for heads of compliance and… Read More
In May, the US Office of Foreign Assets Control (OFAC) published “A Framework for OFAC Compliance Commitments” (“Framework document”). This document consists of two separable parts, the first of which lays out five “essential components of compliance” that OFAC believes should form the basis for a sanctions compliance program… Read More
By Lenin Cavalcanti Guerra, University of Saskatchewan Operation Car Wash is an ongoing investigation by Brazilian federal police into a money laundering scheme in which black market money dealers used small businesses to launder dirty money. If you’ve seen TV shows like Breaking Bad or Ozark, it will… Read More
In December 2016, “the largest foreign bribery case in history” was settled in the United States. It was described as such by the Department of Justice when US prosecutors struck a $3.5 billion plea agreement with Brazilian construction giant Odebrecht and its subsidiary Braskem. The Odebrecht prosecution came amid a… Read More
By Iwa Salami, University of East London Facebook has unveiled libra, a cryptocurrency that will enable users to make international payments over Messenger and other group platforms like WhatsApp – perhaps from as soon as 2020. Here’s how it looks likely to work: a user would buy… Read More
The use of capital markets to launder money via investment banks is a topic seldom raised. There are the headline-grabbing cases, to be sure, such as Deutsche Bank’s trouble with mirror trades or Goldman Sachs’ connection to the 1MDB bonds, but these are rarities that fall short of driving industry… Read More