Category: Money Laundering

Factors influencing the choice of technique to launder funds: The APPT framework

This paper proposes a new framework to provide insights into the techniques launderers adopt to clean illicit funds, drawing on existing literature and theories including rational choice, public value, structural coupling, and stakeholder. The proposed APPT framework is named after four factors that explain the choice of techniques: the Actors involved, Predicate crime, the Purpose of laundering, and Technological innovations. While the current literature on money laundering primarily directs attention toward aspects such as regulatory frameworks, the stages of money laundering, and ways of detecting it, there is a lack of understanding about the reasons underlying a launderer’s choice of…

Artcurial auction house embroiled in provenance row with London Dealer

A London dealer is at odds with Artcurial over a painting he purchased last year, for which he claims that the Paris auction house was unwilling to provide the requisite provenance information to comply with anti-money laundering (AML) rules. Artcurial insists that it adhered to all its obligations at all times, and cancelled the sale last month. Patrick Matthiesen bought Narcissus (around 1640), a work recently reattributed to the French Baroque painter Laurent de la Hyre, for €918,400 (est €200,000-€300,000) on 9 November 2022. The large canvas had no provenance other than a 1929 “anonymous sale” at Christie’s in London.…

U.S. Anti-Money Laundering Vulnerabilities Counter its Efforts to Aid Ukraine, Experts Say

The U.S. is a magnet for the world’s dirty money, financial crime experts say, as they weigh in on how vulnerabilities in America’s anti-money laundering laws counter the country’s efforts to aid Ukraine in its defense against the Russian invasion. Illicit proceeds equal an estimated two percent of U.S. gross domestic product, according to findings in the Treasury’s 2022 Strategic Action Plan. Russian oligarchs, experts note, contribute to this problem by funneling their ill-gotten gains through industries that are exempt from rigorous anti-money laundering checks. And that’s a lot of money. The combined illicit wealth of just three Russian oligarchs…

U.S. Charges North Korean Banker With Crypto Laundering

A U.S. court charged a China-based representative of North Korea’s Foreign Trade Bank with two counts related to laundering illicit crypto proceeds for the benefit of the North Korean nuclear weapons and ballistic missile program, according to a statement by the U.S. Attorney’s Office. Sim Hyon Sop, a 39-year-old North Korean national, is accused of conspiring with traders in China to launder cryptocurrency stolen by North Korea’s hackers by purchasing goods through Hong Kong-based front companies. The second indictment alleges that Sim managed a scheme laundering proceeds from the work of various North Korean IT specialists, who under fake identities…

Money laundering cash couriers smuggled £100 million in suitcases

The National Crime Agency has dismantled a network of criminal cash couriers that laundered more than £100m by smuggling it out of the UK to Dubai in the UAE. Custody images of Beatrice Auty, Jonathan Johnson and Jo Emma LarvinFrom left to right: Beatrice Auty, Jonathan Johnson and Jo Emma Larvin Eleven of the couriers have now been convicted, following yesterday’s guilty verdicts returned in the trial of Beatrice Auty, 26, from London; Jonathan Johnson, 55, and Jo Emma Larvin, 44, both from Ripon in North Yorkshire, and Amy Harrison, 27, from Worcester Park in Surrey, at Isleworth Crown Court.…

Verdict of French court on fine on Rietumu Banka for money laundering takes force

The Supreme Court in France this January rejected Rietumu Banka’s complaint, and the decision on EUR 20 million fine for money laundering has come into force, said Latvian public television’s analytical news program De Facto, citing data from the bank’s annual report. French businessman Nadav Benoussan and his company France Offshore helped clients to hide some of their income to avoid taxes. Benoussan established offshore companies and opened accounts for them in Rietumu Banka – about 300 accounts a year. Clients were issued bank cards, allowing them to withdraw money in France. Some of these accounts were used in VAT…

Financial watchdog puts banks on alert in fight against money laundering via the Post Office

A series of measures designed to reduce the risk of money laundering via the Post Office have today been set out by the FCA. The regulator brought together partners including the National Economic Crime Centre (NECC), industry and government to strengthen controls while seeking to ensure that legitimate customers can continue to use the Post Office for Everyday Banking. The measures set out for banks today include: Post Offices are an important part of protecting access to cash for people and small businesses. FCA research found 6% of adults in the UK used cash to pay for everything over the…

Six charged with money laundering activity at former Danske Bank Estonia

The Prosecutor’s Office charged six people with money laundering crimes Monday, in relation to the now-defunct Tallinn branch of Danske Bank. According to the charge sheet, the former employees of the foreign banking unit of the Danske Bank Estonia branch – five men and one woman – together orchestrated large-scale money laundering at the Estonian branch of Danske in the years 2007 to 2015, in so doing intentionally concealing the real origins of the funds suspected criminal origin which were transferred to accounts at Danske. Evidence gathered in pre-trial proceedings found defendants provided money laundering services to the tune of…

Crypto laundromat which washed €44M in dirty money is taken down in operation by German, US police

POLICE on both sides of the Atlantic today reported bringing down a massive money laundering operation using a cryptocurrency mixer at its heart. Criminals are suspected laundering of 152 000 Bitcoins (worth roughly BILLION) through the ‘ChipMixer’ platform. Much of the dirty money was connected to darkweb markets, ransomware groups, illicit goods trafficking, procurement of child sexual exploitation material, and stolen crypto assets. Officers in Germany and the US said they took down the infrastructure of the “laundromat” platform, seizing about 1909.4 Bitcoins in 55 transactions (approx. €44.2 million) and 7 TB of data. Ransomware actors such as Zeppelin, SunCrypt,…

Financial Crime Watchdog FATF Suspends Russia over Ukraine War

PARIS, Feb 24 (Reuters) – Global financial crime watchdog Financial Action Task Force (FATF) suspended Russia’s membership on Friday, saying Moscow’s war in Ukraine violated the organisation’s principles. FATF is an inter-governmental organisation set up to combat money laundering and terrorism financing by setting global standards and checking if countries respect them. “This is the first time a member of FATF is suspended,” FATF President Raja Kumar told a news conference. “Russia is effectively sidelined from the organisation.” Article Credit: https://www.reuters.com/world/europe/financial-crime-watchdog-fatf-suspends-russias-membership-over-ukraine-war-2023-02-24/

UK Gambling Commission Fines 32Red and Platinum Gaming £7M for AML, Social Responsibility Failures

BRITAIN’S Gambling Commission today fined 32Red and Platinum Gaming with a €7.1M fine for AML and other failings. The Commission said the penalty on the online operator owned by Kindred Group Plc was also to includes social responsibility failures. “These failures highlight clearly that both operators failed to interact with customers in a way which minimises the risk of them experiencing harms associated with gambling,” said Kay Roberts, executive director of the Gambling Commission. The regulator said financial triggers for anti-money laundering reviews at 32Red were too high and not appropriate to effectively manage money laundering and terrorist financing risks,…

What more can Westminster do to fight financial crime?

Having reclassified fraud as a national security threat, the government’s resolve against financial crime – particularly money-laundering – is hardening. But will the new legislative measures it’s considering go far enough? The City of London Corporation’s website boasts of the UK’s status as “the world’s most global financial centre”, but what it doesn’t mention is that this country is also a magnet for international financial crime. The problem has grown to such a scale that the government announced last month that it was classifying fraud as a national security threat – a move that UK Finance, the trade body representing…

U.S. Anti-Money Laundering Vulnerabilities Counter its Efforts to Aid Ukraine, Experts Say

The U.S. is a magnet for the world’s dirty money, financial crime experts say, as they weigh in on how vulnerabilities in America’s anti-money laundering laws counter the country’s efforts to aid Ukraine in its defense against the Russian invasion. Illicit proceeds equal an estimated two percent of U.S. gross domestic product, according to findings in the Treasury’s 2022 Strategic Action Plan. Russian oligarchs, experts note, contribute to this problem by funneling their ill-gotten gains through industries that are exempt from rigorous anti-money laundering checks. And that’s a lot of money. The combined illicit wealth of just three Russian oligarchs…

Understanding the Art Market and Anti-Money Laundering Regulations

The world’s largest art markets lack robust anti-money laundering supervision. This exacerbates their appeal as a destination for illicit finance. In late February, the Financial Action Task Force (FATF) published a report on Money Laundering and Terrorist Financing in the Art and Antiquities Market. The report highlights a series of risk factors that make it appealing to criminals, including widespread secrecy surrounding beneficial owners and transactions, the subjectivity and wide-ranging values of artwork, and the size and global nature of the art market. There is often a legitimate reason for many of these oddities: anonymity prevents bias in the bidding…

The Financial Conduct Authority Is Investigating Suspected Money Laundering Failings At Barclays

Barclays Bank is being investigated by the Financial Conduct Authority (FCA) for suspected failings in its compliance and anti-money laundering (AML) systems. The UK regulator requested an independent review of Barclays’ internal systems under Section 166 of the Financial Services and Market Act 2000. This involves asking an independent firm of experts to review and report on Barclays’ systems and provide recommendations to improve practices in line with AML regulations. The Financial Times reported that there had been a number of incidents where the bank had failed to conduct thorough know your customer (KYC) and AML checks. Although the incidents…

Experts warn UK businesses of imminent changes to anti-money laundering regulations

Legal experts have urged UK businesses to pay close attention to upcoming changes to the 2017 Money Laundering Regulations (MLRs) that will impose further compliance requirements on in-scope firms. In line with the 2022 Money Laundering and Terrorist Financing (Amendment) (No.2) Regulations, from 1 April 2023, businesses subject to the MLRs will have to comply with checks of the register of overseas entities (ROE) at Companies House for dealings with corporate entities. For dealings with trust entities, businesses subject to the MLRs will have to comply with checks of the trust registration service (TRS) that is maintained by HM Revenue…

Police arrest 20 money launderers in Spanish probe into fake invoices, loans and luxury property to channel dirty money

POLICE have arrested 20 suspected money launderers and drug traffickers and seized more than €5.5M in assets, it’s been announced. The operation was led by the Spanish Guardia Civil, with support from the Italian Central Directorate for Anti-Drugs Services (Direzione Centrale Servizi Antidroga), and resulted in the assets and more than 2 tons of drugs. Based in the South of Spain, the criminal network was composed of Albanian, Italian, Spanish and Moroccan nationals, and was led by Italian nationals who evaded capture using forged identity documents. The criminal network used a variety of money laundering methods to obfuscate their drug…

Man Extradited from Peru on International Money Laundering Charges

ALEXANDRIA, Va. – A Belize City, Belize, man was extradited to the United States Tuesday on charges of laundering tens of millions of dollars of drug proceeds on behalf of notorious international drug trafficking organizations. According to court documents, Jianxing Chen, 42, led and controlled a network of couriers who transported cash generated by the domestic sale of controlled substances. Some of the cash came from cocaine sales throughout the United States – including Chicago, Houston, Los Angeles, New York, Atlanta, as well as in the Eastern District of Virginia.  At Chen’s direction, couriers transported drug money across the country…

No questions asked: money laundering thrives in Australia because of professionals willing to facilitate it

Lawyers, accountants and real estate agents can face little scrutiny and there is as yet no action from government to increase regulation. Raids earlier this month by the Australian federal police provided a rare window into the shady world of international money laundering. Australia is far from a model global citizen when it comes to cracking down on money laundering – and property has become a favoured vehicle for organised crime to hide and transfer dirty money. The AFP arrested nine people, including the alleged head of the money-laundering organisation, Stephen Xin, at his Vaucluse home. They have now been…

US Investigators Subpoena Hedge Funds in Binance Money-Laundering Probe: Report

Authorities have not brought charges against the company, which has faced intense scrutiny following competitor FTX’s collapse, the Washington Post reported. Federal prosecutors are investigating the relationship between Binance and U.S.-based hedge funds as part of a broader investigation into the cryptocurrency exchange’s possible skirting of money-laundering guardrails, according to a report by the Washington Post. Heading the investigation is the U.S. Attorney’s Office for the Western District of Washington in Seattle, which, in recent months, has sent subpoenas to firms requesting records of their dealings with Binance, the Post reported, citing two people who had reviewed one of the…

Most Criminal Cryptocurrency Funnels Through Just 5 Exchanges

The crypto money-laundering market is tighter than at any time in the past decade, and the few big players are moving a “shocking” amount of currency. FOR YEARS, THE cryptocurrency economy has been rife with black market sales, theft, ransomware, and money laundering—despite the strange fact that in that economy, practically every transaction is written into a blockchain’s permanent, unchangeable ledger. But new evidence suggests that years of advancements in blockchain tracing and crackdowns on that illicit underworld may be having an effect—if not reducing the overall volume of crime, then at least cutting down on the number of laundering…

FCA penalises Al Rayan Bank PLC for anti-money laundering failures 

The Financial Conduct Authority (FCA) has fined Al Rayan Bank PLC (Al Rayan) £4,023,600 for failing to put in place adequate anti-money laundering (AML) controls. Between 1 April 2015 and 30 November 2017, Al Rayan allowed money to pass through the bank and be used within the UK without carrying out appropriate checks. The firm failed to adequately check its customers’ Source of Wealth and Source of Funds when it was required to make sure the money was not connected to financial crime.  The failings were made worse by the lack of proper training provided to staff about how to handle…

St. Louis Man Sentenced to 19+ Years for Money Laundering

A St. Louis man was sentenced to 19 years and seven months in prison after admitting to his involvement in a methamphetamine operation in southern Illinois. Terrence Thompson, 35, pled guilty to one count of conspiracy to launder monetary instruments. According to court records, Thompson conspired with the co-defendants to distribute more than 500 grams of methamphetamine in the Southern District of Illinois. Law enforcement conducted a search warrant on Thompson’s residence and recovered more than 10 kilograms of methamphetamine. Members of the conspiracy utilized various payment methods to deal the illegal narcotics, including CashApp, cashier’s checks, bank transfers and…

UK Government Expands Enforcement Measures To Address Fraud and Money Laundering

On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in 2023. The bill seeks to build on the Economic Crime (Transparency and Enforcement) Act 2022 (ECA 2022), which took effect on 15 March 2022. (See our 26 April 2022 client alert “New UK Economic Crime and Transparency Laws Take Effect” to review the key provisions of the ECA 2022.) Since that update, the “Register of Overseas Entities” requirements came into force on 1 August…

UK crime agency arrests ‘wealthy Russian’ over money laundering

Britain’s National Crime Agency (NCA) said on Saturday it had arrested a “wealthy Russian businessman” on suspicion of money laundering and other offences as part of a crackdown on corrupt oligarchs. The NCA said the 58-year-old was among three men arrested by officers from the Combatting Kleptocracy Cell (CKC) on Thursday at a “multi-million pound residence” in London. The Russian embassy in London has demanded information from Britain’s Foreign Office on the reasons and circumstances of the detention of the unidentified businessman and the conditions in which he was being held, Russian news agencies said. The man was detained on…

SEC Charges Danske Bank with Fraud for Misleading Investors about Its AML Compliance Failures in Estonia

The Securities and Exchange Commission today announced fraud charges against Danske Bank, a multinational financial services corporation headquartered in Denmark, for misleading investors about its anti-money laundering (AML) compliance program in its Estonian branch and failing to disclose the risks posed by the program’s significant deficiencies. Danske Bank agreed to pay $413 million to settle the SEC’s charges. According to the SEC’s complaint, when Danske Bank acquired its Estonian branch in 2007, it knew or should have known that a substantial portion of the branch’s customers were engaging in transactions that had a high risk of involving money laundering; that…

Santander Fined £108M for AML Failings

BRITAIN’S Financial Conduct Authority (FCA) today announced it has fined Santander almost £108M for AML failures in its business banking division. The FCA ruled the UK division of the Spanish bank had failed to manage its anti-money laundering systems properly – affecting the way it dealt with 560,000 business customers. Between 2012 and 2017 the bank’s systems were not able to verify properly information provided by customers about their businesses. “Santander’s poor management of their anti-money laundering systems and their inadequate attempts to address the problems created a prolonged and severe risk of money laundering and financial crime,” said Mark…

Rabobank Investigated for Suspected Dutch Money Laundering Violations

Dutch co-operative bank Rabobank (RABO.UL) on Wednesday said it is under investigation by public prosecutors in the Netherlands for suspected violations of national money laundering laws. The bank in a statement said it was cooperating with the investigation. The disclosure follows a 2021 warning by the bank that it had been instructed by the Dutch central bank (DNB) to fix its customer due diligence practices and that it was facing a “punitive enforcement procedure.” Rabobank is one of the Netherlands’ three largest banks. Competitors ING Group and ABN Amro incurred massive fines in similar situations, with ING docked $900 million…

Angolan Court orders Seizure of Dos Santos Assets

Angola’s Supreme Court has ordered the “preventive” seizure of assets worth around $1 billion held by Isabel dos Santos, the daughter of the southern African country’s former president, Portugal’s Lusa news agency said on Tuesday. The court document cited by Lusa, dated Dec. 19, said authorities had evidence of alleged embezzlement and money laundering and ordered the seizure of the money dos Santos holds in “all banking institutions”. The seizure also includes all of dos Santos’s shares in Angolan company Embalvidro, as well as 100% of shares in Cape Verde’s telecom company Unitel T+ and Unitel STP in Sao Tome…

EU Court of Justice Rolls Back Anti-Money Laundering Rules

In a stunning reversal, the Court of Justice of the European Union weakened an existing anti-money laundering rule on Tuesday, limiting use of one of the most potent tools against financial secrecy – access to beneficial ownership information. “Beneficial ownership” is the term for who, in reality, benefits from (or owns) a given company or corporate structure. Wealthy individuals, criminals and tax cheats are among those who routinely disguise ownership of such entities, often to hide their wealth from authorities. Organizations fighting for tax equity and reform immediately denounced the ruling. “By requiring corporations and offshore entities to publicly disclose…

NCA secures £50m identified by Barclays as the Proceeds of Crime

The National Crime Agency (NCA) has obtained a ruling from the High Court that allows Barclays to hand over criminal funds to the NCA in a first-of-its-kind civil recovery case. The money – amounting to over £50m – was identified by the bank in a number of accounts and transferred to secure holding accounts. The civil recovery order means that for the first time, legal powers were used to recover the proceeds of crime where the account holders were not named in the court action. Adrian Searle, Director of the National Economic Crime Centre (NECC) in the NCA said: “Identifying…

FCA Fines Gatehouse Bank £1.5m for Poor Anti Money Laundering Checks

The Financial Conduct Authority (FCA) has fined Gatehouse Bank Plc £1,584,100 for significant weakness in its financial crime systems and controls. Between June 2014 and July 2017 Gatehouse failed to conduct sufficient checks on its customers based in countries with a higher risk of money laundering and terrorist financing. Gatehouse also failed to undertake the correct checks when some of the customers were classed as Politically Exposed Persons (PEPs). In one instance, Gatehouse Bank set up an account for a company based in Kuwait to aggregate customer funds. Gatehouse Bank did not require the company to collect information about customers’…

European Countries Top of Basel AML Index

EUROPEAN countries and New Zealand comprise the Top 10 countries in the Basel Institute AML Index. On the other end of the scale, the bottom 10 are dominated by African countries along with Haiti, Myanmar and Cambodia. Finland – whose FATF assessment was also released today – comes out on top of the ratings with Congo ranked bottom stacking up a rating of 8.3 out of 10 for its money laundering risk. Under the Basel AML Index, countries are assessed under 18 indicators including the quality of their AML/CFT Framework, their Corruption and Bribery Risk, Financial Transparency and Standards, Public…

Money Laundering Cases Registered at Agency Doubled in Last 6 Years

Almost 3 000 cross-border money laundering cases have been registered at Eurojust during the past six years. Since 2016, the number of cases brought to the Agency has been steadily rising. Over 600 cases were brought to the Agency in 2021, representing more than double of those registered in 2016.These are some of the findings of Eurojust’s first comprehensive report on money laundering, published on 20 October. Due to its clandestine nature, the global scale of money laundering is difficult to measure, but it is considered to be significant. The United Nations Office on Drugs and Crime (UNODC) estimates that…

Danske Bank Estimates Money Laundering Fines at €2.08b

Danske Bank predicts in its third-quarter report that the United States and Danish governments could fine the bank €2.08 billion for money laundering in Estonia. Danske Bank estimates in its third-quarter review that the solution agreed upon with the U.S. Department of Justice (DOJ), the Securities and Exchange Commission (SEC) and the Danish National Special Crime Unit (NSK) is expected to cost €2.08 billion. The bank previously estimated the potential fine at €200 million. However, Danske Bank said that negotiations with the authorities are still ongoing and it remains uncertain whether a deal could be reached soon. The bank anticipates…

HMRC cracks down on unlawful estate agents

Dozens of estate agents have been fined more than £500,000 for breaching anti-money laundering requirements, HM Revenue and Customs (HMRC) has announced today (11 October 2022). HMRC named the 68 estate agents that have been fined a total of £519,645 for not complying with rules designed to stop criminals laundering money from illegal activity. The fines followed the first prosecution of an estate agent for trading despite not registering with HMRC, to ensure compliance with money laundering regulations. Felix Uwuigbe, Director of Century House Estates Ltd in London, was sentenced to 120 hours of unpaid community service and banned from…

The veneer of legitimacy: professional money launderers and how they impact the legal sector

When we talk about crime, and the harm it causes to communities and individuals, money laundering is rarely more than an afterthought. It shouldn’t be; money laundering is key to organised crime. Without the ability to wash dirty money, criminals would struggle to further their operations and hide their assets. Money laundering underpins and enables organised crime. What are professional money launderers?Professional money launderers – or PMLs – are people who, for a fee, provide services to organised crime groups (OCGs) by laundering the proceeds of their crimes. PMLs launder for multiple OCGs and don’t concern themselves with how the…

Middle East & North Africa Trade based financial crime guide

Today the MENA Chapter of the GCFFC and MENA FCCG launched their jointly developed bilingual Reference Guide for practitioners to assist in improving awareness of trade-based financial crime risks. The guide was simultaneously published as an open source on the GCFFC and MENA FCCG websites and introduced to the market at the London Stock Exchange Group (LSEG) 14th MENA Regulatory Summit 2022 in Abu Dhabi, organized by LSEG under the patronage of the UAE Executive Office of Anti-Money Laundering and Counter Terrorism Finance. TBFC is persistently flagged as one of the most poorly understood risk areas within the anti-money laundering…

AML efforts of European banks hampered by deficient on-boarding

The anti-money laundering efforts of European banks is being hamstrung by failures to manage key customer data and perform proper due diligence, regulators say Banks’ failure to collect know-your-customer (KYC) data and their tendency to manage high-risk customer due diligence manually are hampering their anti-money laundering (AML) efforts, according to regulators in the United Kingdom. Further, many banks’ assessment of financial crime risk has also been found to be inadequate. Some UK banks, are failing to collect customer information such as income and occupation details. In some cases, customer risk assessment frameworks are underdeveloped or non-existent, which translates into poor…

Deutsche Bank in $26.3 million shareholder settlement over Epstein, Russian oligarch ties

Deutsche Bank AG agreed to pay $26.25 million to settle a U.S. shareholder lawsuit accusing the German bank of lax oversight while doing business with risky, ultra-rich clients like Jeffrey Epstein and Russian oligarchs. The preliminary all-cash settlement filed on Friday in federal court in Manhattan requires approval by U.S. District Judge Jed Rakoff, who in June allowed the proposed class action to proceed. Shareholders led by Yun Wang, who traded Deutsche Bank stock in 2018 and 2020, claimed that the bank had known its know-your-customer and anti-money laundering controls were ineffective, and that its share price fell as problems…