Well hello! I’m back, just in time to see something about tennis, which inspired my post title. But you would be disappointed if I did not find a way to turn it around to money laundering, so here goes. After a fortnight away, I have about three trillion emails to read – I may exaggerate. There’s excitement at the FATF, a new Instruction and some job-shifting in Guernsey, and a threat to send reckless bankers to prison. All of which makes perfect sense. But a couple of stories needed careful and close reading because, in the immortal words of a former tennis superstar, you cannot be serious.
On 2 July, as I sat with my feet up on a paddle-steamer, circumnavigating Lac Léman in stately style, the Russian government decided to pardon 100,000 white collar criminals (of whom 13,500 are currently in prison for their offences – including Mikhail Khodorkovsky). Yes: 298 members of the Duma voted to allow white collar criminals off the hook. Well they would, wouldn’t they? Not all cheats, fraudsters and embezzlers will be eligible, though: the amnesty applies only to first-time offenders who compensate their victims and did not use violence. But why, you might ask. Well, according to Russian business ombudsman Boris Titov, who asked for the amnesty to mark Entrepreneurs’ Day on 26 May, it will guarantee a “stable and growing economy”. He claims that many people were convicted of white collar crimes in the 1990s simply so that the authorities could seize their property, and there is plenty of support for this view. But babies and bath-water come to mind.
But the Russians look only slightly mad in comparison with the Argentinians and their new legislation. As explained in this article from the Economist, Argentina’s President Cristina Fernández de Kirchner has hit on a novel way to attract hard currency to her country. At the end of May, the Argentinian government passed new legislation (known locally as “the laundering law”) to allow any amount of dollars from anywhere in the world to find a home in Argentina, with no questions asked. Argentine citizens with undeclared dollars can invest in property and the energy industry without facing questions about or penalties for their previous financial shenanigans. Now, if she can just find a way to get those clever and recently-freed Russian fraudsters to invest the proceeds of their crimes in Argentina…
I hate money laundering 
You wonder why we continue to bother really Susan. Have all our AML and CFT efforts over the last 15 years had any real effect?
Oh Roy, I didn’t mean to cast you into the depths of despond! No, let’s just see these two stories as our AML version of the summer silly season – and, with both Russia and Argentina may featuring on equivalence lists around the world, a timely reminder to MLROs that such lists are merely a starting point and not a “get out of jail free” card.
And I think that our efforts have had some effect – if only to keep the crime of money laundering in the headlines. After all, ten years ago, how often did you read about someone being convicted for money laundering – and now it’s a daily occurrence.
Keep your AML pecker up!
Best wishes from Susan