I went out to dinner last night; I figured that after knocking out the first draft of another AML book (I did mention the other day that I’m working on my UK piggy editions now, didn’t I?), I deserved a plate of spaghetti cooked by someone else. There was a large group of us – some I knew, and some were partners of the people I knew. And one of these unknown partners was fascinated to hear about my line of work.
Now, contrary to what you might think, this is not a good sign. Don’t get me wrong: I am thrilled beyond measure when I find someone “in the business” (i.e. the AML regulated community) who is as bewitched by AML as I am. We can dissect the finer points of record-keeping, consider the ramifications of a wider PEP definition and a public register of beneficial ownership, debate the merits of the objective test, and generally have a high old time. But when it’s a civilian, I am not so pleased. Because I know what is coming.
First I will hear about how some ignorant, unfeeling, pettifogging and probably impotent bank/building society employee prevented them from doing something perfectly innocent by (the cad, the bounder) asking about the source of their money. And then – seemingly unable to stop themselves – they will hint to me about that source. Sometimes, all is well: their squeaky-clean maiden aunt (perhaps a nun) really did die and leave them a fortune. But more often, there will be something just the slightest bit whiffy about it, and this is suggested by the words they use. “Strictly speaking”, or “in some circumstances”, or – my particular favourite – “none of their damn business”. So I listen and smile, craven creature that I am, and store the information away. I think they think that I’m offering a sort of money laundering confessional service – that once they have told me, and I have smiled, they have received financial absolution. It’s a theological matter that they can raise with the prison chaplain; after all, fourteen years should be long enough for that discussion.
Unless the aunt was hiding the money in a sock, they should be able to proof the source of the money. I don’t know from what amount of cash money they start asking questions. I have sold my own gold jewelry at the time the price of gold was the highest. And a few times put several thousand euro in my bank account. They did not need any proof. (yes, they pay you cash for old gold, but they keep a copy of your ID on record, and you have to sign for the sale). However I was once refused to open a bank account in Monaco. I had received 2 years of French child benefits in one go, and wanted to open an account at a bank where my ex was not client. They found the source (French government) suspicious… Perhaps I was guilty by association?
For newer readers of this blog, Claire is the ex-wife of a money launderer, and often has an interesting insight into how her husband used the financial sector – and indeed how her name still crops up from time to time on certain accounts, despite her best efforts to break all ties.
Claire, there is no legal threshold for when you “should” ask questions about the source of money – it’s all a risk-based decision. But people (including criminals), and perhaps because of the cash transaction reporting threshold in the US, seem to think that $10,000 or equivalent is some sort of trigger!
Best wishes from Susan
Very funny. I usually get raised eyebrows and pestered for hints on how to clean dirty money. in In Thailand, where you can open a bank account with only one piece of ID (and they can be bought easily in Bangkok for buttons) , the concept of laundering as a crime has not yet reached the masses. I’d say the farang ‘tourists’ who pop over here to buy up swathes of land or build luxury condominium complexes are probably more aware of AML laws in their own countries. The Thai AMLO has got its work cut out.
Helen, I sympathise entirely – as if we’d give people those sorts of hints! Other readers, please take note of Helen’s comments about Thailand – always handy to have extra information about jurisdictions. (For instance, I didn’t realise that only one piece of ID is needed there.)
And yes, criminals are past masters at comparing AML requirements and sniffing out the weak links in the international chain.
Best wishes from Susan
Thanks Susan. For more information, here’s a link to my Thai bank account story. Best regards, Helen
I’ve never shown more than one piece of ID to open a bank account. Perhaps the reason is that in the UK you don’t have ID cards like we have in most European countries?
Many thanks, Claire and Helen – an interesting point. Claire, in the UK and related jurisdictions, you are right: we don’t have an ID card. And so we require people to show one piece of ID to prove their name, and another to prove their address – even if their ID is an ID card like yours.
Best wishes from Susan