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Tricks of the trade

There are three main methods by which criminal organisations and terrorist financiers move money for the purpose of disguising its origins and integrating it into the formal economy. The first is using the financial system; the second involves the physical movement of money (e.g. using cash couriers); and the third is through the physical movement of… Read More

How Quincecare Lapses Can Cost Banks Millions

Late last year, the UK Supreme Court ruled that a London investment bank was liable for the loss of $204 million from a corporate account after the institution complied with authorised payment instructions from the company’s director. The ruling, which imposed a $153 million penalty against the bank, is… Read More

Brexit Won’t Affect Your Sanctions Program… Much

Brexit is complete-ish and the United Kingdom has moved into the transition period of its departure from the European Union at the end of the year. Companies with UK sanctions obligations will still be required to follow EU policies through December 31st, and even then, differentiations between OFSI lists… Read More
Art has come a long way from the more than 70,000-year-old drawings in the Blombos Cave of South Africa to, in perhaps its most “postmodern” iteration, its appearance in the EU’s 5th Anti-Money Laundering Directive (5AMLD), which was to be implemented earlier this month.  With sales in the global… Read More
On January 23, 2020, the Internal Revenue Service published a news release titled “Global tax chiefs undertake unprecedented multi-country day of action to tackle international tax evasion.” The announcement highlighted a coordinated effort across the United Kingdom, United States, Canada, Australia and the Netherlands to combat money laundering and… Read More
On December 12th of last year, OFAC issued a Finding of Violation (“Finding”) to Aero Sky Aircraft Maintenance, Inc. (“Aero Sky”) for two apparent violations of the Global Terrorism Sanctions Regulations (GTSR). At the time of OFAC’s action, Aero Sky was no longer in business. However, OFAC noted in… Read More
Banks will remain vulnerable to money laundering and other financial crimes unless further action is taken to improve transparency in the company formation sector, experts have said after an investigation revealed how easily shell firms can be set up across the world for illicit purposes. Last month, the Organised Crime and Corruption Reporting… Read More
At the request of the International Consortium of Investigative Journalists (ICIJ), I recently analyzed e-mails and other records documenting some of the communication between PwC auditors and representatives of Fidequity, a financial services company that managed several entities formed in Malta, British Virgin Islands (BVI) and the Netherlands. The… Read More
Officials in the United Kingdom and bankers throughout Scandinavia turned a blind eye to the influx of illicit Russian funds linked to Europe’s biggest money laundering scandals, according to a British financier and anti-corruption activist. In a recent interview for KYC360’s AML Talk Show, Bill Browder spoke to host… Read More
The UK’s first ever cross-government, public-private Economic Crime Plan, a collection of policy, legislative and operational commitments, was published just days before the passing of the baton from Theresa May to Boris Johnson. In this respect, the plan could be viewed as a cuckoo in Prime Minister Johnson’s policy… Read More
Chaos theory is a branch of mathematics that says that random events actually follow patterns that are heavily dependent on the initial conditions. Simply put, how things behave chaotically depends on the initial shove to the otherwise-stable environment – but, ultimately, they are logical, not random. Sadly, this describes the… Read More
Diligent KYC360 readers should take note of the recent action by the US Department of Justice (DOJ) against HSBC Private Bank (Suisse) SA (HSBC) following the bank’s admission that it conspired with American customers to facilitate tax evasion. The bank entered into a Deferred Prosecution Agreement (DPA) with the… Read More
The recent proclamation in The Star that, “In Canada, nearly all accused money launderers get their charges dropped”, didn’t surprise me in the least. I’ve had the privilege of interacting with hundreds of Canadian law enforcement officers and prosecutors who specialize in the prosecution of mafia bosses and money… Read More