Missing presumed safe

A while ago, I wrote a blog post wondering why bookmakers are excluded from the UK’s AML/CFT regime.  Of course, bookies are not the only holes in the system.  Two others that spring to mind are high value dealers in services, and multinational companies that engage in large transactions (e.g. oil companies, transport businesses).  I’ll look at the first of these today, and then make you wait until Wednesday for the second – I’m mean like that.

When High Value Dealers (defined by the Money Laundering Regulations 2007 as those who trade in goods for cash of at least 15,000 euros) were brought into the AML fold, this was the result of much wrangling at EU level.  Several EU member states (among them, I am told but cannot confirm, the UK) campaigned for the definition to be extended to include those who trade in services for cash – but were overruled by others.  Had they succeeded, the UK’s AML regime would now apply also to, for instance, consultancies, schools, colleges and universities (should they wish to accept large cash payments).  And there is plenty of evidence – in the form of examples of known laundering through such places – to suggest that such an extension would make sense.  As always, the problem arises not with the logic, but with the application: if service businesses are brought under the AML umbrella, who will supervise them?  I am sure the Quality Assurance Agency would be both delighted and qualified to take on this new role…