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A day in the life - the MLRO
The ability to deliver and manage a structured response to financial crime risk, report to a board, regulator(s), sometimes law enforcement, as well as lead a team and train staff, not forgetting writing and revising policy and procedures - the MLRO role doesn't want for variety of challenges, Paul Cochrane discovers.
Online Published Date:
01 March 2023
Appeared in issue:
302 - 03 April 2023
Ukraine-Russia conflict [24]: US Treasury expands and intensifies sanctions on Russia, targeting key sectors, evasion efforts and military supplies
On 24 February 2023, the one-year anniversary of the Russian invasion of Ukraine, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced significant actions that targeted Russia's financial services sector, sanctions evasion, Russia's military supply chain, and metals and mining sector. Herbert Smith Freehills elucidates the latest constraints.
Online Published Date:
01 March 2023
Appeared in issue:
302 - 03 April 2023
The chips are down - in Monaco
Popular culture has long considered Monaco the perfect 'sunny place for shady people', writes Keith Nuthall, and judging by the latest Moneyval assessment of the Mediterranean principality, this characterisation holds some truth regarding AML/CFT.
Online Published Date:
07 March 2023
Appeared in issue:
302 - 03 April 2023
Upwards - Andorra
A southern European micro-state with close relations to France and Spain, the principality of Andorra is advancing its AML/CFT controls, according to external assessors. Andreia Nogueiraand Keith Nuthall head into the Pyrenees to check their report.
Online Published Date:
07 March 2023
Appeared in issue:
302 - 03 April 2023
Virtual acceleration, real change - Liechtenstein
Hard to find on a map, it may be, but Liechtenstein has always punched above its size in international finance, and is now making its mark through full embrace of blockchain technology and as a preferred registration venue for virtual asset service providers. Keith Nuthall looks at a rapid evolution and the anti-money laundering response within the country and by external assessors.
Online Published Date:
07 March 2023
Appeared in issue:
302 - 03 April 2023
Wealth One Bank of Canada fined Can$676,500 for risk, reporting, record-keeping breaches
Wealth One Bank of Canada has paid a Can$676,500 (US$491,470) administrative penalty after FINTRAC, the country's financial intelligence unit, identified substantive breaches of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and related Regulations.
Online Published Date:
08 March 2023
Appeared in issue:
302 - 03 April 2023
FinCrime Curator - March 2023
If you're looking for measured, critical inquiry into how to combat financial crime and negotiate the ever-expanding laws and rule sets promulgated by governments and regulators, you could do worse than start by clicking on our carefully selected podcasts.
Online Published Date:
08 March 2023
Appeared in issue:
302 - 03 April 2023
Casino Malta Ltd pays €233,834 for extensive AML failings
A bricks and mortar casino operator in Malta was ordered to pay €233,834 (US$250,565), on 3 March, after the jurisdiction's Financial Intelligence Analysis Unit found widespread breaches of the Prevention of Money Laundering and Funding of Terrorism Regulations during a supervisory review in 2019.
Online Published Date:
13 March 2023
Appeared in issue:
302 - 03 April 2023
FATF urges wide-ranging checks on accuracy of beneficial ownership declarations
The Financial Action Task Force (FATF) has advised governments to take a proactive approach to ensuring beneficial ownership information is correct, using a wide range of data sources and cross-checking declarations for accuracy.
Online Published Date:
14 March 2023
Appeared in issue:
302 - 03 April 2023
Overdue - Luxembourg reforms
Luxembourg, a founding member of the European Union, was long associated with opaque beneficial ownership of companies established in its jurisdiction: all changed with the launch, in 2019, of a public register, which exposed instances of investment and control by criminals, oligarchs and corrupt politicians. Sara Lewislooks at the grand duchy's response to the OpenLux findings.
Online Published Date:
15 March 2023
Appeared in issue:
302 - 03 April 2023
External data sources: key inputs for compliance and investigations
Whether digging through layers of a complex corporate structure to unearth the ultimatebeneficial owners, conducting negative media searches or seeking to trace funds flow through a blockchain, the anti-money launderer (a new term?) will continually be referencing information outside their organization. Keith Nuthall explores resources on offer - both free and paid.
Online Published Date:
15 March 2023
Appeared in issue:
302 - 03 April 2023
Ukraine-Russia conflict [25]: UK and EU augment sanctions, marking invasion milestone
One year on from Russia's invasion of Ukraine, the UK and EU have announced additional sanctions on individuals and entities as well as further trade restrictions. Susannah Cogman and Elizabeth Head of Herbert Smith Freehills study the measures.
Online Published Date:
15 March 2023
Appeared in issue:
302 - 03 April 2023
Typologies - enough said?
Knowing exactly how the launderers operate surely assists in frustrating their designs but then in detailing methods publicly there's a risk of educating other bad actors: at least, that's the logic - does it stand up? Paul Cochrane investigates.
Online Published Date:
18 March 2023
Appeared in issue:
302 - 03 April 2023
Banking-as-a-Service - opportunity and risk management
Banking-as-a-Service (BaaS) brings a whole host of opportunities to both banks and fintechs, writes Farnoush Mirmoeini of KYC Hub. Fintechs can go to market more quickly with new products and create applications that provide new services to their customers. Banks, for their part, have an extra distribution channel, the ability to acquire more customers and the opportunity to cement their position as an infrastructure provider, as well as being a regular bank. Yet while BaaS brings undoubted benefits to the financial services ecosystem, it is important to recognise that it also presents risks to BaaS providers, particularly around financial crime.
Online Published Date:
20 March 2023
Appeared in issue:
302 - 03 April 2023
32Red and Platinum Gaming fined UK£7.1m for AML and social responsibility failings
Two online gaming firms, both part of Kindred Group plc, are to pay a total UK£7.1 million (US$8.7 million) penalty after the UK Gambling Commission found breaches around anti-money laundering and social responsibility.
Online Published Date:
23 March 2023
Appeared in issue:
303 - 01 May 2023
William Hill fined £19.2m in UK over AML gambling and social responsibility failings
The William Hill Group will pay penalties totalling UK£19.2 million (US$23.6 million) after the UK Gambling Commission found that three of its companies had breached anti-money laundering and social responsibility obligations.
Online Published Date:
28 March 2023
Appeared in issue:
303 - 01 May 2023
MEPs push back against ECJ ruling on beneficial ownership register access
Key European Parliament committees have pushed back against the European Court of Justice (ECJ) ruling last November [2022] that said the European Union (EU) had allowed excessive access to beneficial ownership registers, breaching EU privacy rights.
Online Published Date:
28 March 2023
Appeared in issue:
303 - 01 May 2023
Big words - Economic Crime Plan 2.0
A million pounds for every mention of a new strategy, performance framework, collaborative working and other project management terms in the second iteration of the UK Economic Crime Plan, covering 2023-26, might well sum to more than the £200 million investment promised by Government to end of the financial year 2024/25 - plus the other £200 million extracted, some might say extorted, from businesses subject to the Money Laundering Regulations, through the Economic Crime Levy. But the fact is, it's not that much - generously, 0.4% of the more than £100 billion which the National Crime Agency says there is a "realistic possibility" is "laundered every year through the UK or through UK corporate structures".
Online Published Date:
30 March 2023
Appeared in issue:
303 - 01 May 2023