People sometimes ask me how I can bear to stick with just one subject for over twenty years – yes, that’s how long I have been AML-ing. And I simply say that although the subject remains the same, and indeed its definition is fairly unchanging (i.e. money laundering is how criminals attempt to conceal the origins of their money), what is ever-changing is the methods by which they do that. And what also changes is the crimes they commit. Of course you have the basic categories – theft, fraud and so on – but within that, phew, are criminals ever imaginative.
Last week I read about a Oxfordshire couple in their forties, David Rennie and his now-estranged wife Clare. In 2007 they set up an online football memorabilia business called FA Premier Signings, offering for sale signed shirts and the like. But rather than putting in the hard yards [note the sporting metaphor there] and actually – as he claimed on his website – waiting for hours outside venues to get footballers to sign things, David simply bought replica items on the high street and signed them himself to order. Over nine years, he faked autographs by the likes of Cristiano Ronaldo, Lionel Messi and Steven Gerrard on about 4,500 football shirts, boots and balls. This little wheeze made the Rennies about a million pounds, which they spent on fancy cars and long holidays in Florida. It all unraveled when a customer made a complaint to the trading standards people, who made a test purchase: they paid £150 for a Manchester United shirt signed by Wayne Rooney. They then contacted Mr Rooney, and he said the signature was not his. A search of the Rennies’ house turned up bags of unsigned shirts and fake certificates of authenticity. As they say in the best American cop movies: busted. Man and wife were charged with running a fraudulent business and money laundering; Clare pleaded guilty, while David chose to go to trial and was found guilty on 12 January 2018. They will be sentenced next month.
Although the big money laundering stories – the Abachas and the Obiangs, the Sinaloas and the Adams – grab the headlines and the imagination, it is the smaller instances like this that are more instructive. Few of the MLROs reading this will have high profile clients laundering in the multi-millions, but small businesses – such as online sellers of football memorabilia – are the bread and butter of most financial services providers. Sharing stories like this with your staff will reinforce the message that it could happen anywhere, to anyone. And if you can pick a type of business that is actually on your books, you’ll win on penalties too.
The low profile stuff doesn’t attract the same scrutiny and oversight as the ‘big tariff'(not as sexy!!) until it blows up then…!!! Not sure I would like to be in the position of their bankers over the past 10Yrs or so should subsequent investigation throw up any tell tale signs!!
You’re right, CDWOS – it may take more time, but you can be sure that whenever there is a money laundering conviction, there are investigators looking back through all the steps to search for inattentive, ignorant and/or colluding regulated entities and professionals.
On 16 February 2018, David Rennie was jailed for six years: http://www.bbc.co.uk/news/uk-england-43088776