Money Laundering Bulletin

London law firm Clyde & Co and one of its former partners, Edward Mills-Webb, have been fined UK£500,000 and UK£11,900, respectively, after accepting they failed to meet their anti-money laundering obligations in connection with a shipping industry client during proceedings before the Solicitors Disciplinary last week (commencing 8 January [2024]).

The three British Crown Dependencies of Guernsey, Jersey and the Isle of Man have rowed back on commitments made in 2019 to allow public access to their beneficial ownership registers, citing a 2022 European Court of Justice (ECJ) ruling.

Gibraltar-headquartered firm Gamesys, which operates 16 websites - including ballycasino.co.uk, doublebubblebingo.com and jackpotjoy.com - has been ordered to pay UK£6,071,292 after the UK gambling regulator found it had breached rules around anti-money laundering and social responsibility between November 2021 and July 2022.

10 January 2024 saw commencement of the Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (Amending Regulations), which provide for changes to the enhanced due diligence (EDD) requirements in relation to so-called domestic PEPs (i.e. a politically exposed person entrusted with prominent public functions by the UK). Specifically, the Amending Regulations amend regulation 35 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) to require that the 'starting point' of any assessment of the risk posed by a domestic PEP is that they pose a lower risk than a foreign PEP. Susannah Cogman of Herbert Smith Freehills discusses the background to this change, explains the new requirements, and considers the UK Financial Conduct Authority's related work on PEPs.

A tiny Leeward island jurisdiction, population under 45,000, Sint Maarten is working to limit its exposure to criminal money but after a dozen follow-up reports to its most recent mutual evaluation by the Caribbean Financial Action Task Force, it still faces immense challenges, finds Keith Nuthall in this report from the capital, Philipsburg.

A digital currency trading firm, which dealt mainly with institutions and high net worth individuals, has agreed to pay a US$8 million penalty after the New York Department of Financial Services discovered breaches of the State's Virtual Currency Regulation and Cybersecurity Regulation during two examinations.

Corruption is an umbrella term used for a number of unethical and often illegal practices, such as bribery, nepotism, insider dealing and market manipulation. Reflecting on the UK National Crime Agency's charges brought against a former Director of Corporate Banking at First Bank of Nigeria (UK) in December 2023, Mario Menz asks: Do we really know what corruption is?

A detailedUNOffice on Drugs & Crime (UNODC) report has calledon governments in east and southeast Asia to proactivelyprevent the growth in illicit gambling services in the region, which are being abused by money launderers.