Wolves crying wolf

I’m a bit wary of wading into this topic, as I am something of a dunce when it comes to working out political affiliations and machinations – even after watching a gazillion series of “The West Wing”, I’m still not sure who were the goodies, the genuine goodies, the baddies, the ersatz baddies, and the office cleaners (and the office “cleaners”).  But I have noticed in recent months a tendency for accusations of money laundering to be used in the political environment, as a method of making life awkward for someone and getting them out of the way for a while.  As I say, I’m not always convinced that I know what’s really going on in the political arena (who does?), but I am fairly sure that money laundering is not it – or at least, not the heart of it.

Last week, for instance, prosecutors in Nicaragua charged journalist Cristiana Chamorro with money laundering.  Cristiana is the daughter of former president Violeta Barrios de Chamorro – and has indicated that she will run against current president Daniel Ortega in November.  In late May, police raided the offices of the Violeta Barrios de Chamorro Foundation for Reconciliation and Democracy and the offices of the independent news outlet run by Cristiana’s brother Carlos Fernando Chamorro.  And now the Nicaraguan government has said that Chamorro is under investigation for alleged financial irregularities and money laundering related to the foundation; she contends that the accusations are Ortega’s attempt to keep her out of the presidential race.

Journalists are of course frequent targets for regimes that do not value openness and transparency.  In December 2020 Ugandan journalist Nicholas Opio was arrested and charged with money laundering and has been held in prison since then.  It is suspected by many that the charges are politically motivated – to get Opio out of the way – because of his support for opposition leader and presidential candidate Robert Kyagulanyi, known as Bobi Wine.  Friends say that at the time of his arrest, Opio was working on collecting evidence surrounding fifty-six killings and multiple arrests that occurred after protests in November 2020 sparked by the arrest of Wine.

Now, as you can imagine, this annoys me.  Money laundering is a serious and destructive crime, and devaluing it like this – bandying around accusations with no foundation beyond “it’s a handy way to hobble this person who, like everyone, uses money” – is infuriating for those of us dedicated to preventing and punishing real money laundering.  Remember the frustration attending Operation Yewtree (a UK police investigation into sexual abuse of children by celebrities and others), when people worried that having high-profile accusations which did not lead to a conviction would result in future reports of abuse being taken less seriously?  Enormous damage can be done to real investigations into real crimes if politically-motivated pressure is brought to bear on the prosecutorial authorities.  It’s another – as if we needed another – dangerous outcome of corruption, and we must resist it with every ounce of our strength.  Here endeth the rant.

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Lifelong learning

At the start of my working life, I did a self-assessment questionnaire which indicated that my strengths lay in keeping myself to myself (a team worker I ain’t) and in learning more and more about less and less – in other words, I should be an expert.  The word has become devalued (a has-been under pressure, etc.) but the etymology holds true: it is from the Latin experitus, meaning tried, proved, known by experience.  And for nearly thirty years I have concentrated on developing my experience of one subject: AML.  When I first told people of my plans, several counselled against it.  Money laundering is a fashionable bugbear, they said: it will be solved, or people will stop worrying about it, and then you’ll be out of work.  Broaden your reach, they advised: offer training in all the financial crimes and not just money laundering.  I ignored them – not because I knew my market so well, but because all other financial crimes seem so ordinary and dull when compared to money laundering.

And it turns out that my advisers couldn’t have been more wrong – but then so was I.  They were wrong in thinking that money laundering would fade from view, and I was wrong in thinking that I could master AML.  Sure, I think about it all day, most days – and I know the requirements in worrying detail (who knew that one day I too would be quoting sections of legislation as though to the gavel born).  But wow, is money laundering growing complicated and specialist.  I feel I could spend another ten years getting to grips with trade-based money laundering, and then ten more for cyber-laundering.  You remember when your grandma looked at you with astonishment when you programmed the VCR for her?  I get the same look on my face when someone talks to me about crypto-tumblers and DeFi.

So what is an MLRO to do?  Three things:

  • Don’t panic – no-one can expect you to understand every aspect of every form of money laundering
  • Subscribe (often for free) to good, reliable, reputable sources of information – for instance, the executive summaries of FATF typologies reports are invaluable ‘idiot’s guides’ to current money laundering hot topics
  • Enlist the help of the right experts – no, not me, I’m talking about the 18-year old in your IT department who knows everything about crypto.

From a personal perspective, I’m delighted with my career choice – I can’t imagine anything worse than feeling stale, or anything better than working in a subject that keeps stretching the brain cells.

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A nose for trouble

My usual watchwords for this blog are (in ascending order of emotion) “disappointment”, “indignation” and “outrage”.  But this week it is “awwwww”, because it’s all about a litter of cuddly, snuggly puppies.  Last week the Metropolitan Police’s Dog Training Establishment took delivery (groan!) of a litter of seven German Shepherd puppies – the offspring of two working police dogs, so born into the family business.  They are being referred to as the “Ratana litter” in tribute to Sergeant Matt Ratana, who was shot and killed at Croydon Custody Centre in September 2020 as he prepared to search a handcuffed suspect.  All the puppies bear names that refer to Sergeant Ratana and his New Zealand heritage, and their initial training will include tracking human scent, helping to find suspects, and locating guns and knives.  However – and well done for bearing with the story this far – some of them will be trained as cash-sniffer dogs.  And – here’s the best bit – their training is being funded by confiscated proceeds of crime.

In the year to April 2021, cash-sniffer dogs helped the Met Police to recover a total of £47.2 million in notes and coins (up 150% from an already impressive £18.4 million in the previous year).  A spaniel named Millie sniffed out £80,000 during a house search and then led her handler around the property again and indicated a point of interest in the bathroom – when officers took the loo apart, they found a further £185,000 stashed behind the cistern.

Police believe that criminals are currently even more flush (double groan!) with cash at the moment: businesses that would traditionally handle large amounts of cash were closed during the pandemic, and there were fewer opportunities to travel to move money abroad.  Once any identifiable victims have been reimbursed, the residue of any seized cash is distributed to law enforcement agencies across the country.  And the Met is spending theirs on more doggy noses.

Detective Chief Inspector Tim Wright, from the Met’s Central Specialist Crime Command, said: “Our investment in training these new puppies as cash seizure dogs will help us to find cash that is hidden in secret compartments, known as hides, in vehicles and homes – making our work quicker and more effective.  Cutting off the cash flow that is generated by criminality and ill-gotten gains not only helps to tackle violent crime but it also helps to fund extra policing resources.”  Every dog does indeed have its day.

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The wagers of sin

What do Ben Affleck and Jennifer Tilly have in common?  If you said that they were once in a relationship, that’s the wrong Jennifer – Ben was married to Jennifer Garner and engaged to Jennifer Lopez (creating the social media monster known as “Bennifer”).  No, what they have in common is that they are both actors and professional poker players – and given the need for that famous poker face, perhaps acting is good prep for life as a professional gambler.  I mention all this partly to make sure you’re up to date with Tinseltown tittle-tattle [hot news: Ben and Jen Lopez are dating again – it’s Bennifer 2.0] but mainly as an excuse to talk about source of funds and source of wealth.

One of the most common answers to the question “where is your money from?”  (which, however you dress it up, is the essence of all source of funds and source of wealth enquiries) is: it’s from my job.  I earned it, I saved it and now I’m bringing it to you.  If your client has an ordinary sort of job, that’s easy: you ask for a recent payslip or two, and – if you’re unsure of the ball-park – do a job search in the same sector to make sure that the salary they claim is credible.  But what if they have a more unusual job?  (I was recently refused a bank account on the basis that my job – anti-money laundering consultant – sounded dodgy.  So I was turned down by the very thing I live to promote.  Oh the irony.)  And one of the more unusual jobs that is growing in popularity is that of professional gambler.

I don’t mean someone who is addicted to gambling and spends every waking minute and every last penny on it, in an uncontrolled manner.  I’m talking about people who do it as a serious job – and with the explosion in online gambling, their numbers are growing.  Thankfully, with professionalisation has come record-keeping – music to the ears of anyone engaged in CDD checks.  A quick perusal of the Cardplayer.com website, for instance, reveals a comprehensive listing of all major poker tournaments.  Once the tournament has finished, you can click through to see the results – the names of the winners, and the amount they won.  If the tournament has yet to happen, the details for each competition within the tournament include the buy-in – the dues each player pays to take part, which are then put into a prize pool to pay the tournament winners.  In short, you can find out how much it costs to enter, and who won how much at the end of it all.  And *rabbit-hole alert* you can then go to the Global Poker Index to find out about individual players: each profile shows nationality, residence, recent winnings and professional career total winnings, plus a photo.  In case you’re wondering, Ben Affleck has won a career total of US$360,400, which should just about pay for a new handbag for La Lopez.

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Registering my displeasure

When I was a schoolgirl, in the late Victorian era, BO had a different meaning: if some poor soul had BO, you flapped your hand in front of your nose and worked the word “deodorant” into your conversation with them as often as you could.  But nowadays we’re concerned much less about body odour than about beneficial ownership, which almost everyone agrees is a central plank of any AML endeavour.  Sadly, we in the UK have been poorly served by our register of beneficial ownership: since its inception in June 2016, the register of people with significant control has been nothing more than a giant filing cabinet.  As I heard someone describe it so well, those who run it are librarians rather than detectives – they have no power or obligation to validate what they are told.  This means, of course, that the PSC register is all but worthless for AML purposes: it serves as perhaps a second or third corroboration, but certainly cannot be relied upon as a primary check.

And then along came MLD5.  It amended Article 31 of MLD4 to this: “Member States shall require that the information held in the central register [of beneficial ownership] is adequate, accurate and current, and shall put in place mechanisms to this effect.  Such mechanisms shall include requiring obliged entities and, if appropriate and to the extent that this requirement does not interfere unnecessarily with their functions, competent authorities to report any discrepancies they find between the beneficial ownership information available in the central registers and the beneficial ownership information available to them.  In the case of reported discrepancies Member States shall ensure that appropriate actions be taken to resolve the discrepancies in a timely manner and, if appropriate, a specific mention be included in the central register in the meantime.”

How marvellous: thanks to the EU (oh, the irony) the UK government can sidestep the eminently sensible (but costly) step of requiring all submissions to the PSC register to be verified and validated, and instead throw responsibility for pointing out “discrepancies” (i.e. fraudulent submissions) onto the regulated sector and the FIU.  Isn’t this rather like a doctor asking his patient to let him know if he finds a better diagnosis on the internet, so that he can improve his own diagnostic skills?  Useful for the doctor, but rather alarming for the patient.

HMG has been talking of reforms to the system for some time.  In September 2020 it published its response to a consultation on the matter, in which it confirmed that “the Government’s vision is for a register built upon relevant and accurate information that supports the UK’s global reputation as a trusted and welcoming place to do business and a leading exponent of greater corporate transparency”.  However – and more tellingly – it immediately continued: “Companies House will play an even stronger role [my italics] as an enabler of business transactions and economic growth, whilst strengthening the UK’s ability to combat economic crime.”  So that’s the true purpose of the registry, is it, to enable business?  And all this talk of reform cannot disguise the fact that we are starting from an extremely low base.  In Guernsey, for instance, submissions to the Guernsey Registry can be made only by “resident agents”, who are covered by stiff legal obligations to gather and maintain information about beneficial owners – and face heavy penalties if they don’t.  In the UK, on the other hand, that consultation response confirms that it’s all much more informal: “Information on companies may be filed at Companies House by a range of individuals.  They may be people connected with the company, such as a director or some other employee.  Alternatively, information may also be filed by third party agents (professional intermediaries who provide such services, including accountants and trust and company service providers, who should be registered with a supervisory authority).”  Should be registered (and covered by AML obligations) – but might not have bothered, and CH won’t know…  And as for penalties for refusing to verify yourself as a PSC, or indeed lying about it, well, “we will develop a suite of compliance activities and sanctions to ensure that as many PSCs as possible are verified within a certain time period of them confirming that they are the PSC with the company”.  I’m sure those dastardly money launderers are quivering in their boots – there’s little that scares them more than a suite of compliance activities.

So why I am so het up about this?  Well, on 5 May 2021, HMG published “Economic Crime Plan: Statement of Progress”, covering the period July 2019 to February 2021.  (It contains enormous amounts of repetition – but perhaps that’s necessary, when progress has been so slow.)  In the section on “strategic priority six – transparency of ownership”, it confirms that there will be “compulsory identity verification for all directors, People with Significant Control and those filing information on behalf of a company”.  Together with obliging the regulated sector and FIU to report any pesky discrepancies, this will “improve the accuracy of the information on the register”.  And – so important that it’s said twice in the same section – “the outcome should be that the millions of users of the register, including the regulated sectors, can have greater faith in the information, so that it continues to serve its vital role facilitating business transactions and underpinning confidence in our economy”.  As someone immersed in the world of AML, I had quite lost sight of the vital role of such registers.

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Calling a spade an earth spoon

If you’re a fan of the current UK government – and particularly the Eton mess whose name shall not be spoken – I suggest you stop reading now.  For my part, I consider them a corrupt regime equal to that run by the Cheeto-in-Chief across the pond for four years, and I can only hope that our democracy rights itself as theirs has done.  Corruption is actually remarkably easy to spot because the definition is so straightforward: Transparency International defines it as “the abuse of entrusted power for private gain”.  Sure, you can subdivide it into kleptocracy and extortion and embezzlement and so on, but that central tenet holds true: if you use your position of entrusted power to feather your own nest (and the nests of your friends and family) – including by buying support so that you stay in office for longer, for further feathering – then you’re corrupt.  As my niece would have it, with attendant teenage eye-roll, “end of”.

And yet the media seems reluctant to use a word that is so clear.  Instead, they talk of cronyism, or a chumocracy, or sleaze – all of which are revolting, but none of which is a crime.  Is it because the UK has spent so many decades – perhaps centuries – wagging its finger at other corrupt regimes that it would be too embarrassing to admit that it has come home to roost (in that nest so comfortably feathered by a store that is not the skip-furnishing John Lewis)?  But by shying away from naming it as corruption, we give those involved the opportunity to deny it to us and to themselves.

A while ago I watched an absorbing documentary called “The $50 Million Art Swindle”, about Michel Cohen, an art dealer who conned people in the art world out of US$50 million before going on the run.  When the documentary maker puts it to him that what he did was wrong, he shrugs.  It was not theft, he contends: they were loans that I have not yet paid back.  Eighteen years later.  It’s all a matter of what you call it – and telling himself that people gave him the money willingly and it’s just a matter of paying it back means that, in his mind, he’s not a criminal.

And it’s the same in the world of money laundering.  If we let people call it clever accounting, or tax efficiency, or complex structures that you couldn’t possibly understand, we’re giving them permission to deny responsibility for their crime.  Sometimes a spade is clearly a spade.

(And if you’re as sick to the back teeth as I am of the UK government sticking its fingers in its ears and going “Na-na-na-we-can’t-hear-you” whenever anyone asks for a bit of transparency, you might like to follow/support the work of the Good Law Project – dedicated to holding power to account.)

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Gone but not un-rotten

Last week a client asked me a question about dead PEPs, and in looking for the answer I realised that this is not a topic addressed by the regulator.  Which is odd, given that it is the inevitable final status of all PEPs.  Everyone’s AML guidance discusses how you should treat PEPs who have left office, but no-one talks about those who have Left Office in the most final sense of all.  Of course, none of us – I don’t think – is imagining that a corrupt PEP will go on laundering money after death.  As someone put it to me, “the risk of someone laundering money or financing terrorism significantly decreases after they shuffle off this mortal coil”.  But although their activity may cease, their wealth does not disappear – and their heirs are still around, and their close associates are still associated.  So I put the question to my AML-obsessed tribe on LinkedIn, and all sorts of issues were raised and debated.

First, it seems that we must draw a risk-based distinction between PEPs who die while in office, and those who pop their clogs during a long and happy retirement from PEP-dom.  If someone is still in the throes of their position of influence, with access to public money, and then falls off the perch, this is a different risk to someone who has been absent from the corridors of power for some time.  Note that I say different risk – not lower risk – because of course it all depends.  We all know of puppet-master PEPs, who no longer have the public title or profile but very much hold the puppet strings of their successor – as another contributor says, “a former PEP’s level of influence can outlive him/her”.

Second – and this was something that I had not appreciated before, so thanks, tribe – the wording of the specific legislation is important.  In the UK legislation, for instance, we have this: “A relevant person must have in place appropriate risk-management systems and procedures to determine whether a customer or the beneficial owner of a customer is (a) a politically exposed person; or (b) a family member or a known close associate of a PEP.”  In other words, the PEP definition refers to the PEP alone – the obligation is to look for PEPs and then also consider their family and close associates.  But in the Guernsey legislation, we have this: “’Politically exposed person’ means… a natural person who has or has had at any time a prominent public function… an immediate family member of [such a person], or a close associate of [such a person].”  Here, the family and close associates are PEPs as well – generally known as “PEPs by association”, but still PEPs.  The dePEPping arrangements are therefore different: in the UK, family and close associates can cease to be of interest the moment the PEP leaves office (or kicks the oxygen habit) – but in Guernsey, they are subject to the same dePEPping timetable as the headline PEP.

And third, the actual answer is, of course, that it all depends.  As with everything AML, it’s a risk-based decision.  You may have a PEP who left office three years ago, after a worthy career unblighted by scandal, and now squawks his last – you are unlikely to be overly concerned about his widow and what she does with the family art collection.  Or you may have Sani Abacha – dead for more than two decades and still causing trouble.  As my grandma advised me when I told her I was engaged: choose carefully, because you’re lying next to them for a long time.

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The woes of UWOs

Unexplained Wealth Orders are now three years old.  Although many would like to see their reach expanded – divorce lawyers are particularly interested – they remain available only in cases involving PEPs or those suspected of serious criminality.  And indeed, we’ve seen successful examples of both: the PEP contingent has been ably represented by Zamira Hajiyeva (wife of the former chairman of the International Bank of Azerbaijan, and perhaps better known as the woman who spent £16 million in Harrods), while the serious criminals have put forward Leeds businessman Mansoor Mahmood Hussain (ordered to hand over 45 properties and various other assets believed to be the fruit of his connections with murderers, fraudsters, armed robbers and money launderers).  Others wait in the wings, including Donald Trump (whose purchase of two Scottish golf courses might stand a little source of funds enquiry).  But what is the UWO to the MLRO – apart from a pleasing bit of Schadenfreude?  I can see two reasons for MLROs to take a more professional interest in UWOs and their operation and scope.

First – perhaps surprising, given my propensity to assume GUILT when confronted with any sniff of financial misdoings – you might be asked by a client to help them meet the demands of an UWO, thereby allowing them to explain their unexplained wealth.  For instance, they might ask you to confirm to the court that yes, they are your client, and yes, they supplied all CDD information as required, and yes, it all seemed fine to you, and yes, they have conducted themselves with dignity and uprightness throughout their relationship with you.  (They might also ask you to confirm that you have never had the slightest suspicion of any whiff or taint of money laundering in their activity, but of course, this you cannot do.)

And second – which will be more common, I fear – is that UWOs will reveal financial structures, relationships and connections that investigators will then be able (indeed, eager) to unpick.  They will look at every institution and professional involved, and wonder whether they did their AML stuff properly – did they ask the right CDD questions, did they monitor the relationship, and did they report any suspicions promptly (remember, the standard is not “did you suspect”, but “should you have suspected”).

So make sure you keep track of the UWOs that are granted and what happens in response to them.  And if you were involved in selling a golf course to an orange-hued former US president, it might well be your turn next.

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Systems to manual

I have a confession: I love writing AML manuals.  I know, I know – it’s akin to saying that for Sunday lunch I enjoy a nice roast kitten with puppy gravy, but there it is.  Who knows when it started, but I have always relished gathering information, sorting it into a logical order, and then determining the best way in which to communicate it.  Add my Favourite Subject Ever, and I’m in clover.  Rather marvellously, clients do occasionally ask me to redraft their AML manuals; they raise the subject almost apologetically, but I’ve got Word open and a skeleton table of contents in place before they’ve hung up.  But, dear readers, I do see some shockers.

The worst – and most common – mistake that MLROs make with their AML manuals is taking shortcuts.  When something changes, they make the minimum number of edits that they think they can get away with – which means, invariably, that bits are missed.  I know it sounds dull (actually, it doesn’t – but that’s my problem and not yours) but when you change any part of a document you must re-read the whole thing to make sure it still works.  Every single page.  Otherwise contradictions and omissions will creep in (can an omission creep in, or does it slink out?).

Another regular bugbear is inconsistency.  You call it KYC in one chapter and CDD in another.  They’re “high risk clients” in this table and “High-Risk Customers” in that one.  It sounds nit-picking (and what’s wrong with that?) but inconsistencies will lead to uncertainty and misinterpretation.  It’s worth remembering that very few of your staff, no matter what they tell you to the contrary when they sign their form, will read the AML manual from cover to cover.  They will turn to it in extremis, when they need to find reliable and unambiguous information quickly.

And tied to inconsistency is style.  I love a good, wide, illuminating, fascinating range of adjectives as much as the next person.  But the AML manual is not the place to practise your Booker-worthy prose.  Keep it clear.  Keep it repetitive.  If you mean “certified copies of all CDD documents must be obtained and kept on the client file”, don’t say, in the next chapter, “obtain certified copies of the documents” – just repeat exactly the same phrase to make it clear that the standard is unchanging.  Keep it clear.  Keep it repetitive.

It’s been attributed to almost everyone, from Thomas Hood to Nathaniel Hawthorne, Lord Byron and Maya Angelou, but the maxim remains true: easy reading comes from hard writing.  And it’s the responsibility of the MLRO to make sure that the AML manual is very easy reading.

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Loophole in the wall

Cash is a problem during a pandemic.  Cash-intensive businesses like nail bars cannot trade, and takeaway food outlets have turned into delivery hubs with payment in advance by card.  Luckily, anyone desperate to offload their criminal cash has a new-ish option that has been steadily gaining ground.  The cryptocurrency ATM is a freestanding machine that is appearing in the corner of shops, petrol stations and (I’m reliably informed by the Daily Telegraph newspaper) strip clubs, and it will happily swap your cash for cryptocurrencies and vice versa.

The CATM (no-one else calls them that – it’s my own invention and you’re welcome) was something of a novelty when a Robocoin machine opened in the Waves coffee shop in Vancouver in Canada in October 2013.  Europe got its first one two months later, in Bratislava in Slovakia.  CATMs come in two flavours: uni-directional ones allow you to buy cryptocurrency using cash or a debit card, while bi-directional ones allow you sell cryptocurrency as well.  Now you know what a dinosaur I am when it comes to matters cryptocurrency, so you will forgive me for quoting from the admirably clear description in Wikipedia: “[CATMs] look like traditional ATMs, but do not connect to a bank account and instead connect the user directly to a [cryptocurrency] wallet or exchange.  While some [CATMs] are traditional ATMs with revamped software, they do not require a bank account or debit card.  On average, transaction fees are 10-20% but can go as high as 25% and as low as 7%.”

As eny fule no, Bitcoin is having a moment – its value is surging.  And it’s dragging the CATM trend with it.  According to Coin ATM Radar, in February 2020 there were 6,759 CATMs in the world – and today there are 17,868.  Speaking to the Daily Telegraph, Ben Phillips of RockItCoin said that his company now has 900 CATMs installed in the US: “It just appears that more people are using Bitcoin for the first time and obviously more people are continuing to come back and use the machines.  We do add that element of privacy where users can feel secure, like they’re dealing just with us.  They’re not putting any bank information in.”

Whoa there, missy – did you say “adding an element of privacy”?  So people can feed stacks of cash into the CATM and get cryptocurrency added to their e-wallet, all without any pesky financial information being checked?  With the recent publicity about the dangers of – and to – money mules, this is surely a risk area that must be addressed.  Thankfully the regulator has CATMs in its sights: in a speech on 24 March 2021, Mark Steward, (Executive Director of Enforcement and Market Oversight at the FCA) announced that “we have now developed a version of the Warning List, called the Unregistered Cryptocurrency Businesses List, to help consumers and FCA authorised firms identify cryptocurrency firms that appear to be carrying on business in the UK but are not registered with the FCA or sought such registration – we placed the first names on the Unregistered Cryptocurrency Businesses List earlier this month, all crypto ATM firms”.  Sadly, CATMs are also on the criminal radar: at the end of last month, a man in Sydney was jailed for laundering money through CATMs – in this case, money was stolen from people’s cryptocurrency wallets and he then withdrew it in cash via CATMs.  So when lockdown lifts and you return once more to The Saucy Minx Exotic Dancing and Dining Club for Discerning Gentlemen and spot a new CATM in the corner, the strippers might not be the only ones losing their shirts.

Thanks to David Winch for pointing out this issue to me – I do love an AML issue

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