i-law

Money Laundering Bulletin

Questioning transactional logic: Crédit Agricole v Papadimitiou

A recent Privy Council decision goes to the heart of what financial institutions should know about the commercial rationale behind transactions and the source of customers’ funds. Charles Sorensen and Ed Shorrock of Baker & Partners draw..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

US crime pays $300 billion a year, National ML Risk Assessment finds

The numbers are inevitably grey but US Treasury’s best estimate of illicit proceeds generated annually in the country is $300 billion: fraud and drug trafficking account for the bulk of that sum, according to the 2015 National Money Laundering..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

It’s not all beer and waffles in Belgium

Belgium may be at the policy centre of AML/CTF, with Brussels home to the European Commission, source of draft EU ML Directives, but its record on translating words into effective practice is far from satisfactory according to the Financial Action..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

Stings in the sanctions tail

Sanctions impact all sides: Sarosh Zaiwalla of Zaiwalla & Co Solicitors worries that the consequences are not properly considered. Sanctions have become the orthodox diplomatic response of countries that wish to punish others for..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

HSBC AML gaps carry too much risk to publish

If HSBC’s anti-money laundering deficiencies were made public they could be “exploited by those who would promote criminal activity, transfer the proceeds of crime, or evade US sanctions”. The warning comes in a 16-page motion by..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

Of wealth and funds: back to the source

Understanding the source of a client’s wealth and the source of funds are key components of an organisation’s due diligence and thus of its broader money laundering prevention strategy. However, although these terms are used in..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

HSBC pays £28m to Swiss prosecutor at close of laundering probe

HSBC will pay CHF40m (£28m) for “organisational deficiencies” to the prosecutor’s office in Geneva, which was investigating aggravated money laundering at its Swiss private banking subsidiary. The..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

Unexplained Wealth Order needed for police to tackle corruption, says TI-UK

The UK’s asset recovery regime is “not fit for purpose”, according to Transparency International UK, the anti-corruption body. TI-UK research [1] reveals that, in 2014, UK law enforcement refused to allow transactions to go ahead..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

The foreign terrorist fighter: profile and funding typologies

Tracking the flows of money that finance terrorist groups is both difficult and highly resource-intensive. An ever-growing problem, it is the source of much unease within the AML community, writes John Bryne, Executive Vice President of ACAMS, the..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

Charities, financial access and terrorism laws: squaring the circle?

That charities play an essential humanitarian role in conflict zones is a given; that they carry some risk of abuse by terrorists is also generally accepted – which leaves the financial institutions that service them having to trade off..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

The professionals: risk and response in Europe

A problem shared is unlikely to mean a problem halved in AML/CFT and sanctions compliance but it may, at least, point a way forward and foster fellow-feeling, both worthy goals of the Association of Certified Anti-Money Laundering Specialists, which..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

The way Fourth

Another EU Money Laundering Directive, another tandem of smart HM Treasury women set to work: Lucies, French and Makinson, saw through the Third Directive and at the Institute of Money Laundering Prevention Officers conference, Marie-Anne Barnes set..
Online Published Date:  26 June 2015
Appeared in issue:  225 - 26 June 2015

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