At an MLRO workshop in Guernsey last week (terrific day – still recovering my voice after all that AML chat) one of the MLROs came up to me during a break and asked whether I had seen this website, www.replaceyourdocs.co.uk. I had not, and I’m still reeling.
Through this website, you can buy “novelty” documents such as bank statements, utility bills and HMRC notifications. They will populate the document – paper and PDF – with whatever information you request, so presumably you could arrange for someone to be send a bank statement showing a balance of a million quid, or perhaps a P45 suggesting that they’ve been fired. My how we laughed. Throughout the site it stresses that the documents are “novelty”, and on the main page it says in capitals that “ALL OF OUR PRODUCTS ARE DESIGNED TO BE USED FOR THEATRICAL, EDUCATIONAL OR NOVELTY PURPOSES ONLY. IT IS THE RESPONSIBILITY OF THE CUSTOMER TO ABIDE BY THESE TERMS AND CONDITIONS AND ALL RELEVANT LAWS AND LEGISLATION.”
But I must admit that I am struggling with the concept of “novelty proof of income documents” and “all of your novelty proof of address needs”. I understand joke mugs – indeed I use them myself as prizes – and joke t-shirts (“If found, please return to nearest bar”), but joke payslips and bank letters? If they were marked in some way, perhaps with “Gotcha!” in a watermark, that would be something, but apparently “We do not write the word specimen or sample on our utility bills and they look like the original”. The MLRO who told me about it ordered a bank statement from them, and he says the quality was disturbingly excellent – certainly good enough to get through his own employer’s CDD checks.
Of course, we all know that you can get counterfeit documents – but not usually so openly and easily. And why would you want such things? Maybe – and this has only just occurred to me – it’s a sting operation by the NCA.… If that’s the case, my Guernsey MLRO can expect a call any day now.
I hate money laundering 
Copyright infringement might give us an enforcement angle on this website. The companies they are imitating (and actually for that matter, Crown Copyright on HMRC crest) have a commercial interest in protecting themselves form this sort of use. Cease and deist notices all round?
An excellent idea, Robert – over to those readers in law enforcement and the legal community. Actually, wouldn’t it make a really interesting case?
Best wishes from Susan
My employer is on this list. The litigation team are getting a call in the morning!
I think this is probably the best way to deal with the situation, David. If we make a big public fuss, they get loads of publicity and probably more profit – but a few shots across the bow from litigation departments might make them rethink their products. As I say, if it’s made clear that they’re novelties, as they keep stressing, by perhaps comical mis-spellings, or indicative watermarks, then fine – but this seems to me to be crossing the line into counterfeiting.
Best wishes from Susan