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World Money Laundering Report

It would be far more sensible if the UK scrapped its money laundering laws, wrote something comprehensible and properly structured and kept it all in one place. But no, that would make life far too simple. So, we have the latest Act that has to be read in the light of, and which makes amendments to, other legislation. But it's important and so no one can simply say "stuff it" and delete it. As it comes into force, there is a hint as to at least some of the priorities in relation to international financial crime.

Yesterday, Singapore passed its Serious Crimes and Counter-Terrorism (Miscellaneous Amendments" Bill. The Lion City's approach to suspicious assets has logic on its side, but it doesn't work in practice. Here is WMLR's analysis of the relevant parts of the Act and its consequences, including risk for compliance / risk officers.

"She was the sort of woman that, if she told you do do something, you did it," PC Robert Carter is reported to have said when asked why he helped his mother, Tamara Carter, to launder the proceeds of criminal conduct from which she received some GBP850,000. A finding of Gross Misconduct at a disciplinary hearing, plus his mother's conviction, suggest that the constable might shortly be receiving a visit from his former colleagues, perhaps even before the Metropolitan Police decide on his penalty. There's an interesting facet to the Board's decision.

Malaysia is being ever so nice to US headquartered bank Goldman Sachs which, through its Singapore Office, it is now known from the evidence given by one of its former staff, Tim Leissner, to have assisted in the theft and laundering of part of the now infamous 1MDB fund.

The bank, which is now seeking to take on new staff in the relevant department in Singapore, has been asked to give back the estimated USD600 million in fees it took for its assistance. Iit's at least arguable that Malaysia doesn't have to ask nicely: it could just take the money. GS doesn't want to pay out in every direction: it's already accepted the probability of "significant fines" in the US as a result of an investigation there.

Here's a step-by-step guide to getting the money back without the bank's co-operation.

The European Bank for Reconstruction and Development has invited expressions of interest for consulting services for financial institutions in Kyrgyz Republic and Tajikistan. Some of the so-called "partner financial institutions," which in the real world would be called "customers" have, the EBRD says, asked for assistance "to conduct a diagnostics (sic) of their internal audit function and provide them with recommendation to strengthen this area in line with the international best practices."

As the request unfolds it becomes, increasingly, a reason for serious head-shaking.

Recent action in Malaysia is making it clear: cash exceeding relatively small amounts is unwelcome. It's not

A notice, relating to the findings of the Financial Action Task Force relating to deficiencies in the counter-money laundering / anti-terrorist financing regimes of several jurisdictions, has been issued by the USA's Financial Crimes Enforcement Network, FinCEN.

The position relating to PEPs has always been complex but Unexplained Wealth Orders are about to take that complexity to a level previously unthought of.

Financial crime risk management - be it related to money laundering, terrorist financing, fraud or embezzlement purposes, to say nothing of anti-bribery requirements - is expensive. For small businesses, it's cost prohibitive. Compliance is even worse. Is it feasible, permissible, even advisable to share the burden with others?

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