Regular readers will know how I love “crisp” writing: writing that is clear, well-structured, unambiguous and just that little bit elegant. (Compare and contrast with most of the hurried, rambling and frankly inaccurate drivel that appears online these days.) Two of my favourite and most reliable sources for such written marvels are the Law Society of England and Wales (their practice notes are a masterclass in lucidity) and RUSI – the Royal United Services Institute, and more specifically their Centre for Financial Crime and Security Studies.
In the early summer, the CFCSS of RUSI published one of their occasional papers – this one on the topic of money laundering risk in the UK professional services sectors (“in particular the legal, accountancy, real estate, and trust and company service sectors”). The report shares the findings from two workshops held in early 2019 and looks first at the money laundering threats facing these sectors and then at the responses to those threats. The threats presented could be the baddies in a peculiar panto: we have the Oligarch and the Organised Crime Launderer. And the standard responses – risk-based approach, CDD and suspicion reporting – are considered for their effectiveness in countering these threats. And, as is the RUSI way, the report is topped and tailed with recommendations.
However, the most interesting part of the RUSI exercise is sadly missing. As explained the introduction to the report, “it was decided to hold one session looking primarily at threats and vulnerabilities (threat workshop) and one looking at the responses of the professions (response workshop). A further session, the red team exercise, was designed to allow attendees to draw up their own money-laundering scheme. The outputs from this session are naturally not included in this paper.” I can only hope they are being shared in a less public forum, as they will prove invaluable.