As you may have gathered, I’m rather keen on the old AML malarkey. I was very , very lucky to stumble into it – having scraped through all my numerical exams by sheer bloody-mindedness, I would never have chosen or been recommended for a career relating to finance in any way – and am grateful every day for having a job that fascinates, absorbs, challenges and only sometimes frustrates me. But I do have to be realistic, and face the fact that – if we all do our jobs properly, and with a following wind – I should be hoping that our collective AML efforts will eventually make me redundant. So when new research comes out into the scale and form of money laundering, particularly locally, I read it avidly. (Well, I open it, put “laundering” into the search box, and page through it looking for those bits – I’ll get back to firearms and cyber crime later, so to speak.)
Yesterday the UK’s National Crime Agency (NCIS/SOCA as was, from the AML perspective) published its annual “National Strategic Assessment of Serious and Organised Crime“. (By the by, I have noticed that sometimes it is “serious organised crime”, and sometimes it is “serious and organised crime”. Have they had to change to the latter because of all those organised criminals who like a laugh, or the serious ones who are just plain chaotic?) This is not a hugely detailed document – it is, as it says, a “strategic assessment” – but it does devote lovely space to money laundering, and to its cousins economic crime and cyber crime. The distinctions become harder to draw, of course, and the NCA acknowledges this by referring to “cross-cutting crimes”.
But looking specifically at money laundering, there is the admission (which will make a guest appearance in much of my training over the coming year) that “Many hundreds of billions of pounds of international criminal money is almost certainly laundered through UK banks, including their subsidiaries, each year”. Now for some key questions.
- What makes the UK so attractive?
“The high transaction volume (estimated at trillions of pounds a day), language, developed financial services industry, and political stability of the UK.”
- How are the launderers doing it?
“Most proceeds of UK serious and organised crime are laundered through UK banks, wire transfer companies and other regulated businesses including Money Service Businesses (MSBs) and cash-rich businesses. A large proportion is sent abroad where profits are often ultimately invested in real estate. Importantly, a proportion is re-invested into criminal activity in various stages of any serious and organised
- Who else is involved?
“Many criminals rely on professional enablers such as businesses that register
and run ‘shell’ companies and trusts in numerous ‘off shore’ areas. Illicit profits are often laundered through cash rich businesses. Complicit, negligent or unwitting
professionals in financial, legal and accountancy professionals in the UK facilitate money laundering. Specialist money launderers, some overseas, manage laundering for multiple criminal enterprises.”
So it looks as though our jobs are safe for a while – is that what’s known as a silver lining?