![]() HMRC publishes its recommended checks on its website: “Know your customer” due diligence checks must always be carried out, such as references checks to verify identity, and the identity of whoever that customer is acting for. Money laundering guidelines are not secret. Anything less than a fully integrated national scheme will mean the most devious criminals will adapt to the individual, separate systems that MSBs put in place and the directors who run these businesses will continue to be at risk of prosecution. Velocity checking looks at trends and patterns of behaviour to spot suspicious activity, in particular the sort of behaviour made up of multiple transactions that are, on the face of it, innocent. We know from working a high proportion of MSBs in the UK that there is a need and a demand for a coordinated system that protects them from criminal activity, and that it is impossible to achieve piecemeal. SCL is calling on the MSB industry to cooperate in a UK-wide system of velocity checking to combat money laundering. ![]() With money laundering connected to terrorism in the eyes of legislators, the pressure to clamp down is only likely to increase. As criminals get ever more sophisticated, they will go further to make their transactions look as innocent as possible.Īccording to the Serious Organised Crime Agency, more than £1 billion a year is currently laundered through UK Money Service Businesses, and London has been dubbed the ‘Money Laundering Capital of the World’. Also, they may not know that if they fail to prevent money laundering, there’s a possibility of spending two years reflecting on this failure from jail.īut, just as money laundering is used to disguise money made through crime, criminals will also attempt to conceal the laundering itself. Ultimately, senior managers at MSBs are responsible for the risk assessment to identify where their business is vulnerable, as well as for the policies and procedures that manage the risk of money laundering. Proving malice isn’t necessary to secure a conviction – instead, a failure to deal with money laundering, whether deliberate or through ignorance, is enough for a crime to have been committed. In fact, it almost demands the opposite, writes Ray Stanton ![]() However, anti-money laundering legislation cuts through this Gordian knot at a stroke – it doesn’t require a ‘controlling mind’. Proving a controlling mind has always made evidence against a company tricky – who is really in charge? In 1844, an English judge by the name of Edward Thurlow summed up the difficulty in bringing a company to justice: “they have neither bodies to be punished, nor souls to be condemned”. ![]() Directors and senior managers of Money Services Businesses that fail to prevent money laundering now face up to two years in prison, and an unlimited fine. ![]()
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