I work regularly in the UK and four UK-related jurisdictions, and for those five I take pains to learn their AML legislation, regulation and guidance. When it comes to the other jurisdictions of the world and their AML regimes, I take a passing interest. And in my most recent passing, I have spotted something of a trend: extension and expansion. Countries are taking their existing AML legislation and extending it.
India, for instance, recently announced that it is going to extend its current AML requirements – CDD, record-keeping and the like – to what they call “property dealers”. They have taken this decision after a 2016 study into irregularities in the real estate sector revealed that an estimated 5.7 lakh crore rupees [that’s 5.7 trillion rupees, or about £68.5 billion] of criminal money had been used to buy property.
In Taiwan they are – perhaps unsurprisingly – more concerned about the financial misdoings of PEPs. And there they have decided that at the end of June 2017 their AML legislation will expand to require EDD to be conducted not only on retired as well as current PEPs (which was the original suggestion for an amendment) but also the friends, family and lovers of PEPs. Taiwan is a conservative society, and the idea of digging into the private lives of PEPs has caused quite a stir.
And now I read that the Philippine Congress has had enough of criminals laundering money through the country’s gambling sector – notably US$81 million stolen in 2016 from the Bangladeshi central bank in a “cyber-heist” – and has voted in an amendment which adds casinos to its AML family. This comes just ahead of a deadline set by the Asia/Pacific Group on Money Laundering (the FATF-style regional body that had expressed concerns on the matter) – and just in time for the July opening of an understated new casino resort in Manila by Japanese gaming magnate Kazuo Okado.