Author: gracechurchfcp

Vatican court convicts cardinal Angelo Becciu of embezzlement

Fraud, Prosecutions
A Vatican court on Saturday sentenced a once powerful Italian cardinal to five years and six months in jail for financial crimes at the end of a historic trial. Angelo Becciu, 75, a former adviser to Pope Francis who was once considered a papal contender himself, is the most senior clergyman in the Catholic church to face a Vatican criminal court. He and nine other defendants, including financiers, lawyers and ex-Vatican employees, were on trial over accusations of financial crimes focused on an opaque London property deal. Court president Giuseppe Pignatone read out the verdict on Saturday, with Becciu accused…

Joint action in Germany and Italy against money laundering via rental of luxury cars

Money Laundering
Eurojust has assisted the German and Italian authorities in a coordinated action against large-scale money laundering through the fake long-term rental of mainly luxury cars. Seven suspects were arrested across the two countries for using a car hire agency to launder the proceeds of drug trafficking, extortion and illegal betting for other criminals. The enterprise has been seized in addition to a real estate complex and nearly one hundred mainly luxury vehicles.The criminal network primarily used a German-registered car rental agency, which rented out over 150 vehicles for periods of three to four years to customers in Italy. Via fake…

Key findings from Phase 2 of Travers Smith review

PEPs
NatWest Group (NWG) has today published the key findings and recommendations from Phase 2 of the Travers Smith independent review – commissioned by the Board in July – relating to account closures at Coutts over the 24-month period prior to 28 July 2023. The key findings and recommendations report (the report) published today was compiled by Travers Smith. The Phase 2 review analysed 84 customer account closures – including all relevant PEP cases exited over the relevant period – building a total sample of around 10% of relevant account closures in the period. The report confirms that decision-making was consistent…

Treatment of Politically Exposed Persons under the Money Laundering Regulations

Legislation, PEPs
My Noble Friend the Treasury Lords Minister (Baroness Vere of Norbiton) has today made the following Writen Ministerial Statement. Today the Government has laid The Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (SI 2023/1371) a Statutory Instrument to amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) in relation to the treatment of Politically Exposed Persons (PEPs) who are entrusted with prominent public functions by the UK (known as ‘domestic PEPs’). The amendment makes clear that under the Regulations the starting point for banks and other regulated firms in their…

New strategy to tackle organised crime

Organised Crime
A new strategy aimed at tackling the growing threat of serious and organised crime has been announced by the Home Secretary as the government steps up action to clamp down on criminal gangs operating in and against the UK. The National Crime Agency (NCA) estimate that there are at least 59,000 people in the UK involved in serious and organised crime and that it costs the UK at least £47 billion each year, equating to the cost of building around 450 new hospitals or supplying around 730,000 more affordable homes outside of London. The new strategy, which builds on the…

UK to remain global centre of ‘dirty money’ without offshore registers, MPs say

Money Laundering
Britain will remain the global centre of “dirty money” unless ministers revive stalled plans for public registers of who owns companies based in offshore havens such as the British Virgin Islands (BVIs) and Jersey, campaigners and senior MPs have said. The veteran anti-corruption campaigner Dame Margaret Hodge MP said it was a matter of national security to do away with the secrecy offered by the 10 inhabited overseas territories and three crown dependencies. In 2020, the government gave the overseas territories, which include the BVIs, Cayman Islands and Bermuda, a deadline of December 2023 to introduce public registers of corporate…

Ladbrokes and Coral owner to pay £585m to settle HMRC bribery inquiry

Bribery, Corruption
The owner of Ladbrokes and Coral has agreed to pay almost £600m to settle an investigation into alleged bribery at a business it owned in Turkey. Entain said it had reached an agreement with HM Revenue and Customs which will make the gambling giant pay a total of £585m in the form of a financial penalty and a “disgorgement of profits”. Under the terms of the agreement, the penalty, which includes an extra £20m charitable donation and a contribution of £10m towards the costs incurred by HMRC and the Crown Prosecution Service (CPS), will be paid in instalments over four…

SFO recovers £250,000 tennis club debenture from convicted fraudster

Asset Seizure
Today at Southwark Crown Court, the Serious Fraud Office (SFO) confiscated £250,000 from Achilleas Kallakis, one of the convicted fraudsters behind the UK’s largest ever mortgage fraud, held at the prestigious West London sports club, The Queen’s Club. SFO investigators identified the £250,000 debenture by tracing the funds through a complex chain of offshore accounts, including a purported family trust, to his £740 million fraud. Mr Kallakis’s name was displayed prominently alongside other notable members on the Debenture Board in the club’s reception in return for the debenture that he purchased in 2007. He also received club membership and access…

The EBA consults on new Guidelines on preventing the abuse of funds and certain crypto-assets transfers for money laundering and terrorist financing purposes

Digital Currencies
The European Banking Authority (EBA) today launched a public consultation on new Guidelines on preventing the abuse of funds and certain crypto-assets transfers for money laundering and terrorist financing purposes. These ‘travel rule’ Guidelines specify the steps that Payment Service Providers (PSPs), Intermediary PSPs (IPSPs), crypto-asset service providers (CASPs) and Intermediary CASPs (ICASPs) should take to detect missing or incomplete information that accompanies a transfer of funds or crypto-assets. They also detail the procedures all these providers should put in place to manage a transfer of funds or a transfer of crypto-assets that lacks the required information. These Guidelines aim…

Lawmakers call for EU crackdown after ICIJ’s Cyprus Confidential revelations

Corruption
European Union lawmakers have criticized Cyprus for its lax enforcement of sanctions against Russia and called for loopholes in anti-money laundering systems to be closed in the wake of revelations from the Cyprus Confidential investigation. During a European Parliament session in the French city of Strasbourg, the officials also debated over the need to speed up ongoing negotiations to better coordinate criminal penalties for sanction evasion across the bloc. The parliamentary session was called in direct response to the latest investigation by the International Consortium of Investigative Journalists, in partnership with Paper Trail Media and 67 media outlets. The project,…

Modern Slavery and Human Trafficking: An Expanding UK Market

Human Trafficking
This is the second in a series of articles on the top 10 serious and organised crime threats to the UK and their evolution over a decade. This article traces the journey of the threat posed by modern slavery and human trafficking, which has risen rapidly up the policy agenda over a decade. Across the globe, supply chains of every description are tainted by exploited labour. The UK is no exception: here as elsewhere, labour is often the greatest cost to business. Reducing this cost offers the fastest route to increased margins. For some businesses, they will use whatever means…

British Reinsurance Brokers Resolve Bribery Investigations

Bribery, Corruption
Tysers Insurance Brokers Limited (Tysers) and H.W. Wood Limited (H.W. Wood), two U.K.-based reinsurance brokers, have agreed to resolve investigations by the Justice Department into violations of the Foreign Corrupt Practices Act (FCPA) arising from Tysers’ and H.W. Wood’s participation in a corrupt scheme to pay bribes to Ecuadorian government officials. Tysers and H.W. Wood each entered into a three-year deferred prosecution agreement (DPA) with the department in connection with a criminal information filed in the Southern District of Florida charging both companies with conspiracy to violate the anti-bribery provisions of the FCPA. “Tysers and H.W. Wood have admitted to…

U.S. Treasury Announces Largest Settlements in History with World’s Largest Virtual Currency Exchange Binance for Violations of U.S. Anti-Money Laundering and Sanctions Laws

Digital Currencies, Money Laundering
WASHINGTON — The U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and IRS Criminal Investigation (CI), has taken unprecedented action to hold Binance Holdings Ltd. and its affiliates (collectively, Binance) accountable for violations of the U.S. anti-money laundering (AML) and sanctions laws that protect American national security and the integrity of the international financial system. Binance is the world’s largest virtual currency exchange, responsible for an estimated 60% of centralized virtual currency spot trading. Today, Binance settled with FinCEN and OFAC for violations of the Bank Secrecy Act (BSA)…

SFO secures conviction of solicitor for tipping off client about money laundering investigation

Money Laundering
Today at the Old Bailey the Serious Fraud Office (SFO) secured the conviction of William Osmond, a solicitor, who disclosed confidential details about an investigation and forged a legal document in an attempt to mislead investigators. Osmond, co-founder of a London-based commercial and property law firm Osmond & Osmond Solicitors Ltd, is the first ever solicitor the SFO has prosecuted with “tipping off” a client. Solicitors are legally obliged not to share details of money laundering investigations into their clients. Osmond was also the acting Money Laundering Reporting Officer for the firm, meaning he was expected to report any suspicions…

Leading firm fined £101,000 for anti-money laundering failures

Money Laundering
A leading South-West law firm has been fined £101,357 for failing to act over money laundering red flags on three property transactions, two of which may have involved a sanctioned entity. The Solicitors Regulation Authority (SRA) said both the fee-earner and the compliance team at Exeter-based Ashfords missed, did not adequately act on or sufficiently record the red flags, demonstrating “a failure in the firm’s client onboarding and ongoing monitoring processes”. This resulted in the firm receiving “significant sums into its client account in the absence of source of funds evidence”. Ashfords accepted the fine in a regulatory settlement agreement…

Binance chief Changpeng Zhao pleads guilty to money laundering charges

Money Laundering
The Binance chief executive, Changpeng Zhao, has resigned after pleading guilty to money laundering violations. “I made mistakes, and I must take responsibility. This is best for our community, for Binance, and for myself”, he said in a post on X. The Justice Department said it was requiring Binance, the largest crypto-exchange in the world, to pay $4.3bn (£3.4bn) in penalties and forfeitures. It said Binance had helped users bypass sanctions across the world. “Binance enabled nearly $900 million in transactions between US and Iranian users, and facilitated millions of dollars in transactions between US users and users in Syria,…

UK cracks down on gold and oil networks propping up Russia’s war economy

Sanctions
Foreign Secretary announces 29 new UK sanctions targeting individuals and entities operating in and supporting Russia’s gold, oil and strategic sectors. new UK sanctions target 29 individuals and entities operating in and supporting Russia’s gold, oil and strategic sectorsthose sanctioned include Russia’s largest gold refiner and international networks propping up Russia’s gold, oil and finance industriesto date the UK has sanctioned over 1,800 individuals, companies, and groups under our Russia sanctions regimeTwenty nine individuals and entities operating in and supporting Russia’s gold and oil sectors have been sanctioned by the UK today [8 November]. New listings include both Russian oligarchs…

United States and United Kingdom Take Coordinated Action Against Hamas Leaders and Financiers

Sanctions
WASHINGTON — Today, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed its third round of sanctions targeting Hamas-affiliated individuals and entities since the October 7 Hamas terrorist attacks on Israel. This action designates key Hamas officials and the mechanisms by which Iran provides support to Hamas and Palestinian Islamic Jihad (PIJ). Today’s designations are coordinated with action by the U.K. and are aimed at protecting the international financial system from abuse by Hamas and their enablers. The U.S. Department of State is concurrently designating a leader of PIJ’s military wing. “The United States will continue to…

Taiwanese authorities seize $320M in country’s largest crypto laundering scheme

Digital Currencies, Money Laundering
The case has surpassed all previous records of money laundering investigated by the Criminal Investigation Bureau in Taiwan Taiwan authorities have arrested an individual suspected of laundering a record 10.4 billion Taiwanese dollars ($320 million) via digital assets. This marks the largest single case of crypto-related money laundering in the island nation’s history. Identified only by the surname Qiu, the suspect was arrested in June upon his return from a trip to Southeast Asia, according to Taichung’s Criminal Investigation Bureau and local media. The case emerged from an investigation initiated last year into a fake securities trading app. A probe…

US Regulators Agree to Ramp Up Oversight of Systemically Risky Non-Banks

Regulation
In a significant policy shift, U.S. regulators have cleared the path for an increased oversight of asset managers, hedge funds, and other non-bank financial institutions that are perceived to pose potential risks to the country’s financial system. This move marks the revival of a robust regulatory framework that had been sidelined during the previous administration of President Donald Trump. The Financial Stability Oversight Council (FSOC), led by the Treasury Department and composed of other major federal agencies, has also introduced a new framework aimed at identifying impending risks within the financial system. This decision is an integral part of the…

France demands EU corruption-busting watchdog with teeth

Corruption
France wants the European Union to create an independent watchdog authority to fight corruption in the EU institutions, which have been rattled by ongoing scandals in recent months. France’s President Emmanuel Macron and French Secretary of State for European Affairs Laurence Boone are proposing an independent anti-corruption body that would have powers to check officials’ income and spot conflicts of interest, Boone told POLITICO’s Brussels Playbook. And now they’re pushing for other EU countries to endorse the plan. Earlier this year, the European Commission proposed the creation of an ethics body with lofty goals but no enforcement power to impose…

ADGM introduces the worlds first DLT Foundations Regime

Digital Currencies, Regulation
The Registration Authority (RA) of Abu Dhabi Global Market (ADGM) officially released the Distributed Ledger Technology (DLT) Foundations Regulations 2023, marking a significant milestone in the evolution of digital assets regulatory frameworks across the region and at an international level. This newly implemented legislative structure is designed to provide a comprehensive framework for DLT Foundations and Decentralised Autonomous Organisations (DAOs), enabling them to operate and issue tokens recognising the unique needs of the Blockchain industry. This new regime comes in line with ADGM’s strategy to foster initiatives in the broader blockchain and digital asset realm. By setting a global benchmark…

Singapore’s DBS Takes a Hit from Money-Laundering Affair

Money Laundering
Singapore’s largest bank, DBS, is grappling with financial exposure of approximately S$100 million (US$73.8 million) in connection with a recent money-laundering scandal that has rocked the city-state, according to the bank’s chief executive, Piyush Gupta. He made this revelation during a press briefing on Monday, shedding light on the bank’s involvement in the ongoing investigation. Gupta disclosed that DBS had provided financing for property purchases involving individuals or companies currently under investigation by Singaporean authorities. In August, the local police made headlines when they arrested 10 foreign nationals on charges that include fraud and money laundering, sending shockwaves throughout the…

Cyprus Wing of Auditing Giant PwC May Have Breached Sanctions in Work for Oligarch

Sanctions
As Russian tanks rolled into Ukraine in late February 2022, staff at the Cypriot wing of international auditing giant PwC were rushing to tie up the sale of hundreds of millions of dollars’ worth of assets owned by Russian oligarch Alexey Mordashov. Like other pro-Kremlin billionaires, Mordashov — described by Forbes as Russia’s richest person in 2021 — was at risk of having his European assets frozen if authorities sanctioned him in response to the invasion. At PwC Cyprus, staff exchanged documents marked “URGENT” and “PLEASE APPROVE” as they prepared paperwork to sell Mordashov’s stake in German travel company TUI…

Portugal’s corruption scandal spells trouble for EU’s critical minerals hunt

Corruption
BRUSSELS — The European Union’s hunt for raw materials is running into new roadblocks — at home and abroad. Portuguese Prime Minister António Costa’s recent resignation over a corruption probe in connection with lithium mining concessions in the north of the country has just dealt another blow to Brussels’ ambitions to diversify its supply of raw materials needed for green and digital technologies. Currently, the EU relies on imports to satisfy its rapidly growing hunger for lithium, a key ingredient in the batteries that power electric vehicles, with China accounting for 60 percent of global battery cell production. Brussels is…

Following Investigations by Tether, OKX, and the U.S. Department of Justice, Tether Voluntarily Freezes 225M in Stolen USDT Linked to International Crime Syndicate

Fraud
20 November 2023 — Tether, the largest company in the cryptocurrency ecosystem, and leading global crypto exchange and Web3 technology company OKX, today announced that they have assisted the United States Department of Justice (DOJ) in an investigation that led to Tether proactively and voluntarily freezing approximately 225 million in USDT tokens in external self-custodied wallets linked to an international human trafficking syndicate in Southeast Asia responsible for a global “pig butchering” romance scam. The joint investigation was conducted using tools from blockchain analysis firm Chainalysis, and the action by Tether represents the largest-ever freeze of USDT in history. During…

Ukraine unveils corruption probes into reconstruction schemes

Corruption
KYIV, Nov 21 (Reuters) – Ukrainian authorities on Tuesday announced investigations into two lawmakers on suspicion of involvement in attempts to bribe top reconstruction officials, part of a closely watched campaign to stamp out high-level corruption. Kyiv has stepped up efforts to fight graft as it pursues membership of the European Union and prepares to receive billions of dollars in Western aid to rebuild from Russia’s ongoing full-scale invasion. The National Anti-Corruption Bureau of Ukraine (NABU) said it had caught one of the lawmakers, a member of parliament’s anti-corruption committee, allegedly offering the country’s first-ever documented bribe in bitcoin. Investigators…

DWS Agrees to Pay $25m for AML Violations and ESG Misstatements

Money Laundering, Prosecutions
The Securities and Exchange Commission (SEC) has taken action against registered investment adviser DWS Investment Management Americas Inc. (DIMA or DWS), a subsidiary of Deutsche Bank AG, for multiple violations related to Anti-Money Laundering (AML) programs and misrepresentations regarding Environmental, Social, and Governance (ESG) investments. As part of the settlement, DWS will pay a total of $25 million in penalties. Anti-Money Laundering Violations: In the AML enforcement action, the SEC’s order determined that DIMA caused mutual funds under its advisement to fail in developing and implementing an AML program consistent with the requirements of the Bank Secrecy Act and applicable…

OFAC Sanctions Mexican and Colombian Nationals Involved in Sinaloa Cartel

Digital Currencies, Sanctions
On September 26, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 10 individuals involved in illegal fentanyl, cocaine, and methamphetamine trafficking into the United States on behalf of Mexico’s Sinaloa Cartel. As we’ll explore below, one of those individuals controls an Ethereum address that was included as an identifier on his SDN List entry. Today’s actions represent a coordinated effort between OFAC, the Drug Enforcement Administration (DEA), the Government of Mexico’s La Unidad de Inteligencia Financiera, and the Colombia Counternarcotics Working Group. Who are the sanctioned individuals and what did they do?Nine of…

EY Pays Back £15m to Santander UK

Money Laundering
SANTANDER UK’s fincrime consultants EY have paid back £15M to the bank – and no longer work for the lender, it’s been revealed. A dispute between the banking giant and the Big Four has led to the prospect of redundancies in EY’s fincrime division in the UK. EY had been recruited to work on the bank’s so-called “Project Morgan” but there was a dispute over the quality of assistance, which has now resulted in the multi-million pound refund and termination of contract. The dispute centred on the quality of work performed by EY which Santander claimed was poor, leading the…

Why keeping the UAE on FATF’s ‘grey list’ makes no sense to me

FATF, Money Laundering
June 23rd, 2023, the Financial Action Task Force (FATF) have requested continued focus on the Action Plan for the United Arab Emirates (UAE) and won’t be taking the UAE off the grey list early. In fact, the UAE has completed all the requirements to be taken off the list, however, the FATF traditionally does not automatically remove a grey listed country when this happens and they wait to see a continuing trend of compliance with its requirements. Initially, on 4th March 2022, UAE was added to the list of jurisdictions under increased monitoring (“Grey List”) by the FATF. Grey Listing…

U.S. Company Pays Hundreds of Millions After Alleged Bribery in Asia

Bribery, Corruption, Regulatory Fines
American chemical manufacturer Albemarle Corporation has agreed to pay more than $218 million to settle allegations of bribing officials at state oil refineries in three Asian countries, the U.S. Justice Department announced Friday. The North Carolina company admitted to using “third-party sales agents” and foreign employees to bribe officials to win contracts with state refineries in India, Indonesia and Vietnam, the department said. The department said Albemarle received nearly $100 million in profits from the corrupt scheme. Under the Foreign Corrupt Practices Act in the United States, it is illegal to bribe any foreign official in exchange for obtaining or…

India: Government weaponizing terrorism financing watchdog recommendations against civil society

Counter Terrorist Financing
Indian authorities are exploiting the recommendations of a global terrorism financing and money laundering watchdog to target civil society groups and activists and deliberately hinder their work, said Amnesty International in a new briefing released today. “Weaponizing counter-terrorism: India’s exploitation of terrorism financing assessments to target civil society” reveals how the recommendations of the Financial Action Task Force (FATF)—a global body responsible for tackling terrorism financing and money laundering—have been abused by the Indian authorities to bring in draconian laws in a coordinated campaign to stifle the non-profit sector. These laws are in turn used to bring terrorism-related charges and,…

Cyprus to Tighten Crypto Regulations in Accordance with FATF

Digital Currencies, Regulation
One of the friendliest European jurisdictions to crypto, Cyprus, might bring its industry regulation to tighter standards. According to an Oct. 10 report by the Cyprus Mail, the Cypriot Ministry of Finance intends to amend the existing Prevention and Suppression of Money Laundering and Terrorist Financing Law. The ministry has presented its amendments package to the House of Representatives Standing Committee on Legal Affairs, Justice and Public Order. It seeks to align Cyprus with international standards for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) set by the Financial Action Task Force (FATF), as well as the recommendations of…

Indonesia’s Former Agriculture Minister Named in Corruption Probe

Corruption
An Indonesian former government minister has been named as a suspect in a corruption probe and accused of pocketing more than US$800,000 of public money, a week after resigning from his post. Syahrul Yasin Limpo, who until recently led the agriculture ministry, is the sixth minister investigated over corruption since President Joko Widodo took office in 2014. Graft remains rampant in the massive archipelago nation, where politicians are widely seen as among the most corrupt. Limpo regularly took “illegal levies from civil servants at the agricultural ministry to pay for his and his core family’s personal needs”, Johanis Tanak, deputy…

FinCEN Proposes New Regulation to Combat Money Laundering and Terrorist Financing

Counter Terrorist Financing, Money Laundering, Regulation
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has taken a significant step in the fight against money laundering and terrorist financing by announcing a Notice of Proposed Rule Making (NPRM). This NPRM identifies international Convertible Virtual Currency Mixing (CVC mixing) as a class of transactions of primary money laundering concern. The move comes in response to growing concerns regarding the extensive use of CVC mixing services by various illicit actors worldwide, including state-affiliated cyber actors, cybercriminals, and terrorist groups such as Hamas, Palestinian Islamic Jihad, and the Democratic People’s Republic of Korea (DPRK). The proposed rule…

Switzerland Probing Hamas Financing: Attorney General

Counter Terrorist Financing
The Swiss judiciary is investigating possible financing of Hamas from Switzerland despite the country not classifying the group as a terrorist organisation, its attorney general said Saturday. The investigation was opened “several weeks” before the October 7 attacks by Hamas on Israel, Stefan Blaettler said, on Swiss public radio station SRF, without revealing further details. The Attorney General’s office later told AFP that the investigation was launched “on suspicion of financing Hamas from Switzerland”. The investigation is expected to be laborious because, unlike the European Union and United States, Switzerland has not placed bans on Hamas. But since the attack,…

Albania’s Former PM Sali Berisha Faces Corruption Charges Over Land Privatisation Scandal

Corruption, Money Laundering, Prosecutions
Sali Berisha and his son-in-law face corruption charges related to the alleged misuse of political influence, and Berisha is barred from leaving the country.Albania’s former prime minister Sali Berisha says that prosecutors have charged him with corruption and money laundering in connection with a land deal involving a Tirana property.Berisha, 79, said the prosecutor’s office in charge of cases against senior officials or major cases, ordered him not to leave the country. Berisha also said his son-in-law, 50-year-old Jamarber Malltezi, was arrested on the same charges at Tirana International Airport. Berisha said both he and Malltezi are innocent.“On these charges…

UK’s Economic Crime and Corporate Transparency Act receives Royal Assent

Money Laundering, Regulation
Robust laws to fight fraud, counter corruption and bolster legitimate business received Royal Assent today. The Economic Crime and Corporate Transparency Act introduces world-leading powers which will allow UK authorities to proactively target organised criminals and others seeking to abuse the UK’s open economy. Companies House will receive enhanced abilities to verify the identities of company directors, remove fraudulent organisations from the company register and share information with criminal investigation agencies Law enforcement agencies will benefit from greater powers to seize, freeze and recover cryptoassets, while groundbreaking legal reforms will allow the courts to dismiss spurious lawsuits which seek to…

Money Mules Special Edition

Money Laundering
Hello and welcome to the 22nd issue of the UKFIU’s magazine SARs in Action. In this special edition wefocus on the issue of money mules, starting with an article examining common indicators of money mule accounts… Article Credit: https://www.nationalcrimeagency.gov.uk/who-we-are/publications/675-sars-in-action-issue-22/file