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I do realise that I am fairly judgmental when it comes to money laundering: in my opinion, all crimes are bad, and laundering is one of the worst as it enables all the others. But perhaps my position is not the common one. What do you think? Is money that falls into your lap now yours, or would keeping it be — in effect, when it comes to looking at the proceeds and the laundering thereof — theft? You can watch it yourself here. Graham of the yacht advertises said yacht for sale, meets an undercover reporter to try to flog it, boasts about his property in France, supplies videos of himself roofing that property and sailing to the Azores not at the same time, of course — do pay attention — all while claiming disability allowance and council benefits in Croydon.

Stephen also claims a council flat from Croydon — while owning a smart pub in Devon and driving a Bentley to the cash and carry to stock up on crisps.


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Not exactly living quietly, is it? So was I outraged?

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Was I surprised at the cleverness and ingenuity of these criminals? I must say that I expect even criminals to show pride in a job well done, but this lot, they were a shambles. When I first started providing AML training, back in the days when dancing and cookery programmes on the telly featured professionals rather than celebrities who fancied a go at our expense, it was quite hard to find real-life examples.

All the theory was there, and you knew that it happened a lot, but when people asked for genuine case studies, my heart sank. Fast forward to , and whoa Nellie! And they are absolute gold dust for training because they are often so mad and so ordinary at one and the same time. Take this one , for instance: Aussie criminals caught in a flat full of cocaine and cash — and the washing machine and bath are both full of notes being washed.

Who knows. And then here we read that the Spanish police have arrested a gang smuggling cocaine by forming it into Manolo Blahnik shoes that their couriers then wear from Colombia to Spain — genius!

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Autumn must be the season for indices, as we have had a bumper crop of them recently. I talked about the Financial Secrecy Index a few posts ago , and then Transparency International flexed their indexing muscles with the East African Bribery Index — which revealed that the most corrupt country in that part of the world is Burundi, while the most bribery-prone institution is the Ugandan police bet they paid TI to say that. So just who is paying all these bribes?

Of course, all of this is but an appetiser, an amuse-bouche if you will, while we wait for the Godfather of Indices, the Head Honcho of Rankings, the Big Cheese of Classifications and Compendia — the Corruption Perceptions Index. Of course, not all economic crimes are created equal, and so my attention turns at once to the pieces that deal with my true love: money laundering.

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There are very clear explanations of the legislation PoCA and the Regs — which just now strikes me as an excellent name for a band, something a bit bluesy and mournful, for smoke-filled nights and angst-ridden mornings , and the offences and penalties. And there are some good, clear explanations of landmark cases such as R v Da Silva I have just noticed that I now have 20 subscribers and there have been 1, viewings of my blog. Lovely round numbers, and large with it. Thank you all. I am sure that JK Rowling and Dean Koontz are loading the printer paper tray in readiness, but for some of us the figures will fit comfortably onto one sheet.

As you may have gathered, I hate criminals. These are the ones who use their understanding of finance to steal from others. Less grubby, maybe, but definitely more sneaky and just as damaging — and very much on the increase.

The little devils are even joining the army to learn skills to teach their fellow gang-members. I flatter myself that one of my major functions — apart from AML training — is to make it easier for MLROs and other ML-obsessives to find and sift the information they need to do their jobs better and more efficiently.

But even I have to admit that perhaps I am trying too hard. I have this blog. I have some information that I reserve to send to client MLROs, so that they feel particularly adored. So when I read an ML story, I have to decide: is this for fast distribution on the Stop Press page, or wry comment on Facebook, or rambling discussion on this blog, or limited distribution to much-beloved MLROs? Sign me up! Yes please!

Suspicious Activity Reports (SAR)

Cutting and pasting into your own blog and taking the credit, or using it to make a fortune from your own e-book? No thank you. Oh, and illegal. Enter your email address to subscribe to this blog and receive notifications of new posts by email.

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AML Compliance Program

McHugh C. Box C. Date C. Jackson Grayson C. Lakin C. Moore Clifford D.

The European Fifth Anti-Money Laundering Directive Kicks in On January 10th

Lawrence D. Lindley D. Westlake Donald Kiffmeyer Donald M. Goldstein Donald Waters Donella H. Maoshing Ni Dr. Michel Cohen M. Bright Wilson E. Hemmings F. Steege H. Mallory Hadley V. Cutler Howard Chaykin Howard R. Carson Black J. Lukas Neely J.


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