Well, you knew it had to come: an Olympic-themed post. I have yet to attend the hallowed event myself (Graeco-Roman wrestling on Monday – I know you’re green with envy) but I have been following with interest a little-reported side of the Games: the warnings put out to businesses about how to adjust their risk-based approach during these weeks of frenzied sporting endeavour. HM Revenue & Customs, for instance, are the supervisory body under the UK’s Money Laundering Regulations for Money Service Businesses, High Value Dealers, and Trust or Company Service Providers and Accountancy Service Providers not supervised by someone else. And HMRC has put out some handy guidance for such businesses on handling the predicted influx of business from foreign visitors during the Games and on spotting dodgy transactions, warning – almost certainly correctly – that “criminals may use the increase in legitimate business generated by the Games as a cover for laundering criminal funds”.
In a briefing published in April, the Law Society of England and Wales warned of the increased danger of fraud: “With so many people visiting London for the Games, all competing for reduced resources, and with many visitors being unfamiliar with their surroundings and legal requirements in the UK, many individuals could find themselves more vulnerable to fraud.” Law firms were advised to watch out for cloning of their websites, an increased use of fraudulent passports, many more PEPs visiting our shores, and people answering the (very good due diligence) question “Why use our firm?” with “Well I was just in the country for the Olympics and while I was here thought I would …”.
And just in case it does all go for a Fosbury Flop, the Serious Organised Crime Agency – which has been warning about Olympic threats for quite some time – has released a specific Suspicious Activity Report (SAR) code: if your SAR relates to the London Olympics in any way, you should make sure that it features the code XXLO2012XX, so that it can be dealt with by the right people. And no, that’s not James Bond and the corgis.