Unlike the hero of the song by The Kinks, money laundering does not frequent discotheques and parties, but in many other respects it is like him: money laundering pursues all the latest fads and trends, it can be found in Regent Street and Leicester Square, and it is as fickle as can be. For yes, money laundering is indeed a dedicated follower of fashion. And as we come to the end of the year, it is time to look back on the trends of 2012.
The really big fashion this year was bribery – or, as all trends need a catchy name, ABC (anti-bribery and corruption). The SFO put out guidance and then retracted it, Transparency International lost patience and published its own “Adequate Procedures” – and MLROs around the world were besieged with requests to provide their staff with ABC training and procedures. Which is a shame, as there is very little to base it on: given the lack of cohesive governmental guidance, we’re having to rely on common sense and the expectation of case law to clarify the more knotty issues.
Also all the rage in 2012 has been the unfolding fate of HSBC – and, to a lesser extent, Standard Chartered. Previously unheard-of regulators have popped up to deliver their verdict and demand their portion, and AML trainers have been picking over the bones for the big messages to pass on, but sadly we lack that stunning punchline: “And then these directors and account managers were sent to prison for a really long time.” And just peaking in the last couple of months has been the latest craze: man’s inhumanity to man. Stories of people trafficking, slavery, forced labour and worse have been crowding the headlines – along with tales of how the profit (always enormous) is being laundered. Even more sickening than peplums and shoulder-pads is hearing that the Connors family swanked around in a Rolls Royce while their slaves worked for £5 a day.
So as 2013 approaches, and with it plenty more AML training and MLRO workshops for me, I wonder what the big money laundering stories will be. One thing we know for certain is that money laundering is always in fashion (oh yes it is, oh yes it is).
I am taking a little break over Christmas, so my next post will appear on Wednesday 2 January 2013. I wish you and yours a very merry Christmas and a happy new year.