A blast from the past

Image via Wikipedia

Hi,

This post has nothing to do with money laundering but a great deal to do with fun.
In this case The 1980 Harvey's Casino Bombing. The link in the title takes to a short video clip of the event with background and narration by the FBI agent involved. Please note that no one was hurt in the making of the film. I also find it vaguely reassuring to note that human behaviour won through and that gamblers in Las Vegas used this rare event to make book on something new.
Enjoy.

If you go down to the woods today....

On the 28th August 2009 the US Drug Enforcement Agency (DEA) published highlights of a raid in Colorado that occurred a week earlier. In a joint operation with both national and local agencies, the DEA announced the seizure of approximately 14,500 live marijuana plants and the arrests of two suspects that occurred on Friday, August 21, 2009, in the Pike National Forest, Colorado.

The seizure is believed to be the largest outdoor marijuana growing operation ever detected by law enforcement in Colorado. Thanks to the DEA for the picture of the crop which is shown above.

The following is a direct quote from the DEA website "The marijuana was being grown in the remote, rugged terrain of the Pike National Forest near Deckers, Colorado. As agents advanced on the grow site, an estimated seven to ten individuals were seen running from the area. Their sleeping bags and food items were recovered at the site. Information developed during the investigation determined that Mexican migrant workers had been recruited from outside the state of Colorado to harvest the marijuana plants, which were found to be between four to six feet tall."

Interesting to note that the cultivation appeared to be dependant on a migrant (probably illegal?) workforce and that the cultivation attempt was on a large scale in a remote part of the National Park. Money laundering the profits from such a venture would only have been the tip of seriously organised criminal conspiracy.

Are Scottish Politicians Soft on Terror? II

Image via Wikipedia

The BBC have just conducted an opinion poll of 1005 Scots about the, in my view, disgraceful release of the convicted Lockerbie bomber. Terrorism needs to be resisted by our elected representatives, not rewarded by them.

It is reassuring to see that 70% of those disagreed with the Scottish politicians who made this decision. Here is the link to the details of the BBC poll: http://news.bbc.co.uk/1/shared/bsp/hi/pdfs/28_08_09_megrahipoll.pdf

This does appear to reaffirm the opinion of the blogosphere that this decision has harmed Scotland and the Scottish Prime Minister of the UK, Gordon Brown. Next time Mr Alex Salmond, the leader of the SNP, derides the opinion of bloggers as being unrelated to the real world whilst politicians have to make "hard choices", perhaps he could live by his words and make the "hard choice" of LISTENING TO HIS ELECTORATE when it comes to dealing with convicted terrorists.

Given that he is a professional politician who wishes to split up the UK, I have to say, fat chance of that happening.

Come on everybody, it's registration time!

You will recall that when the UK implemented the 3rd EU AML Directive in December 2009, it also made 22 existing organisations (like the AIA and IAB) responsible for regulating their members for the purposes of identifying and preventing money laundering and counter terrorist financing.

One of the new organisations which gained AML oversight responsibility was the UK Government’s Office of Fair Trading (OFT).

The following types of business are supervised by the OFT and will need to register:

• Consumer Credit Financial Institutions. These are businesses carrying on consumer credit lending activity who are neither authorised by the Financial Services Authority nor money service businesses supervised by Her Majesty's Revenue and Customs.

• Estate agents. This covers those engaged in estate agency work as defined by Section 1 of the Estate Agents Act 1979.
  

From 31st July 2009, the OFT now requires all its supervised businesses to register before the 31 January 2010. Fees would appear to range from £115 to £2,300.

Failure to register could lead to the OFT imposing a civil penalty or taking a prosecution if business is carried on after 31 January 2010. Prosecution could result in a sentence of up to two years in prison and/or an unlimited fine.

Remember, if you are supervised by the OFT you need to:

1. Register with the OFT before the 31 January 2010 - see Registration page.
2. Comply with the Regulations - including
a) confirm customer identity and ongoing monitoring of business relationships
b) keep records for 5 years from the end of the business relationship or, if an occasional transaction, the end of the transaction
c) appoint a Nominated Officer
d) implement risk based compliance policies and procedures, and
train staff in law and procedures.
3. Make Suspicious Activity Reports

From an economic point of view, the timing isn’t brilliant.

However, it is now time to implement your new systems, register and comply.

The First Golden D'oh Award!

Image by striatic via Flickr

Well having been sounding off recently, it was inevitable that I'd be brought up short. In this case by a close friend who, whilst diligently following this blog, pointed out that it was impossible to leave comments on it!

He didn't buy the "it's the only way to to keep it secure & spam free" argument and I had to admit to a rookie error on how I'd set this blog up. So it is only fair that the initial Golden D'oh! award for an outstanding / funny cock up should be awarded to "The AML Watchman Blog!" itself.

Still I'm quietly confident that that Gordon and the boys will launch an all out attempt to muscle in on this occasional, if prestigious award.

So, dear reader, please feel free to now engage in this moderated version of Web 2.0.

Whilst I will allow anonymous postings, it will only be after the comment has been checked.

So be brutal, you know you want to!

Trainspotters = Mostly Harmless (unless your Dyfed Powys Police)

View Larger Map

Has combating terrorism and universal CCTV become the acceptable excuse for the UK abandoning that expensive idea of policing by consent?

I’ve already blogged about my concerns that the Police are using anti-terrorist legislation to curtail legitimate oversight of their activities (http://www.anabscenceofbalance.blogspot.com/2009/07/is-all-cash-over-1000-now-dirty-in-uk.html )and of my concerns that they will police the compliant rather than difficult criminality.

I also worry that when it comes to modern policing the use of the phrase “possible terrorist” has become the excuse for abandoning proportionate, sensible and decent behaviour. If this is accurate then this could be a huge problem for the AML / CTF regulated sectors.

Why? Well, here we go again. The Daily Mail today carry’s a report of a trainspotter, Mr Stephen White, whose enthusiasm for hobby led him to photograph some unmarked train engines in use at the strategically important oil depot in Milford Haven (Picture from Google Maps). The civil servant was on holiday in Wales with his sister and her two young children. Mr White and his sister’s car (especially its number plate) registration were caught by CCTV operating in the oil depot.

According to the this UK national paper there then followed what might only be described as a litany of police activity which might remind readers of either the Stasi or Keystone Cops (delete as appropriate) in their heyday. Have a read and decide for yourself.

What worries me most about the sort of behaviour described in the article (assuming it’s an accurate record) is the following:
1. That it is this sort of behaviour that alienates people. It will drive a wedge between the Police and the community that they are allegedly serving.
2. Was there a police officer responsible for evaluating and co-ordinating this activity?
3. Was the person experienced enough and or afraid to use their judgement?
4. If so, why did they pursue their enquires so vigorously once they had met Mr White?
5. Are the police using photographic information to achieve their ends whilst attempting to deny members of the public their legal hobbies using cameras?
6. Why are the Police afraid to admit that they may have been heavy handed and apologise for their actions? After all, the UK Government’s mantra is “If you have nothing to hide you have nothing to fear”. Or is that just a slogan that doesn’t apply to the State?

Were this an isolated incident and or Mr White, his sister or his young niece and nephew in some way related to recent Islamic terrorists or Irish Republican terrorists (Who Have Not Gone Away, BTW!) one might have some sympathy with the way at least two forces conducted themselves.

However, it is the most recent of a long line of incidents. Take this quote from a similar news story in the Independent on January 2009: http://www.independent.co.uk/news/uk/home-news/photographers-criminalised-as-police-abuse-antiterror-laws-1228149.html

“Jeremy Dear, the general secretary of the NUJ, said: "It's time the police realised that taking photographs doesn't automatically mean you're a terrorist. Every month the NUJ finds itself dealing with yet more cases of officers infringing journalistic freedoms and, very often, exceeding their legal powers.

"Even the police's own guidance makes it clear that there's nothing in the Terrorism Act that can be used to prohibit the taking of photos in a public place. The authorities have got to do more to ensure that those people charged with upholding the law don't keep on contravening it by trampling over well-established civil liberties."”

My concern remains that whilst senior police officers rely on CCTV rather than effective policing, then they fail to protect civil liberties and actually appear to be undermining them. Combined with supine Labour MP’s failing to hold Gordon Brown’s government to account, then in the UK the struggle against continuing terrorism will be undermined.

Why? Because if you the police continue to alienate law abiding citizens going about their normal lives, whilst building the Government’s DNA database on the quiet and they then also overreact to normal day to day life (by failing to exercise reasonable judgment), then they may well come to be seen as ineffectual, politicised problem who are too dangerous to talk to.

IMHO, the natural reaction of the British public will be to have less day to day contact with the police, which in turn could decrease actual information flow vital to identifying and preventing actual terrorists rather than trainspotters.

That can only increase the chances of a seriously dangerous terrorist nutter getting through.

Birkenfeld Gets 40 Months in jail

Image via Wikipedia

The Washington post has reported that Bradley C. Birkenfeld, a former banker for Swiss banking giant UBS and who helped U.S. officials uncover billions of dollars in taxpayer money in secret bank accounts was sentenced on the 21st August 2009.

He pleaded guilty last year to the criminal charge of assisting UBS (and some of its US clients) evade the USA’s tax collectors, the Internal Revenue Service. As he is still helping the authorities with their enquiries, he will start his term on 8th January 2010.

Mr Birkenfeld had asked to be sentenced only to probation, federal prosecutors had asked that he be given 30 months but in the end a federal judge gave him 40 months. The sentence does leave me wondering about whether the Judge accepted his motivation for blowing the whistle as being entirely pure?

Channel 4 News Coverage of al-Megrahi

It is not just me is it? Where is "our glorious leader" G. Brown? As at 22nd August 2009.

A moment to reflect

Image via Wikipedia

On this Sunday morning, when the victims of terror appear to have been forgotten by Scottish politicians in the UK, perhaps you could take a moment to remember the the 270 victims of Pan Am flight 103 that ended over Lockerbie on 21st December 1988.

If the the price of freedom is eternal vigilance, then we should remember how our UK elected politicians behaved over this affair and punish their parties accordingly.

Are Scottish politicians soft on convicted terrorists?

Image by Getty Images via Daylife

Followers of this blog will recall that it was set up to try and help review the actions of those who "represent us" in our elected governments. Indeed you'll find right at the top of this blog "Yet the individual client has virtually no say over what various national governments and their competing departments are doing to their rights and liberties in their name. This blog attempts to address the dilemma posed by the question “Quis custōdiet ipsōs custōdēs?”"

The recent release of the only person to be convicted of the Pan Am Flight 103 /Lockerbie atrocity is, to my mind, an excellent case in point.

UK politicians have imposed on UK businesses and individuals draconian laws ostensibly with a view to to combating terrorist finance. You may care to link back to an earlier blog entry on the UK's approach to fighting the terrorist threat. http://anabscenceofbalance.blogspot.com/2009/08/kafkaesque-terrorist-freezing-orders-uk.html

However, when it comes to how they behave themselves, it is totally a matter of "compassion" for a convicted mass murderer. The way in which the Scottish politicians in particular have deported themselves over the last week, whilst British and American troops are conducting a war in Afghanistan, has appalled me.

I have been trying to not to vent my spleen at the release of the terminally ill Al Megrahi by the SNP's "honourable" Kenny MacAskill, MSP (pictured) or the absence of leadership, inaction or representation of English interests by our Scottish Prime Minister the "Right Honourable" Gordon Brown MP.

Instead, I shall let you read the letter from FBI Director Robert S. Mueller, III, to Scottish Minister Kenny MacAskill.

Once you have read it, I'll leave you make up your mind whether you think Scottish politicians are soft on convicted terrorists

The FBI's most wanted Terrorists

The Widget below should be fairly self-explanatory. Should you have any comments or questions, please don't hesitate to say so!

The FBI's 10 Most Wanted

This is more for our American cousins / readers but also because it is such a groovy way of getting the information out there!

Implementation of the 3rd AML Directive

Image via Wikipedia

The AML buffs amongst you will recall that the Member States of the European Union had to transpose the 3rd AML Directive (Directive 2005/60/EC) into national law by 15 December 2007 at the latest. As if that was going to happen!

Anyway, the European Commission published an update in July 2009. They now say that almost all Member States have fully aligned their national legislation with this Directive.

The list of exceptions, however, makes for interesting reading:
§ The Republic of Ireland and Spain where the implementation measures are still pending;
§ Belgium, France and Poland have only partially implemented the Directive.

Interestingly all Member States which had not yet adjusted their legislation were referred to the European Court of Justice (ECJ), which is pictured above; two have been already convicted by the ECJ for their failure to transpose the Directive within the period prescribed: Ireland on 19 May 2009; Sweden on 11 June 2009 (Sweden has in the meanwhile fully implemented the Directive).

I would suggest that all those firms and individuals who conduct business with the relevant laggards familiarise themselves with the current state of play in these countries and adjust their risk matrices accordingly.

"Double Standards Of Tax Amnesty May Deter Disclosures"

Association of International Accountants: (AIA)


In a useful article linked to above, PKF Accountants are quoted as outlining a subtle difference between the current and previous Offshore Tax Amnesty scheme. In short the last scheme run by HMRC was matched by a virtually identical scheme in the UK. This time the supporting UK scheme is not on offer. So the advice is still to take advantage of this offer but don't expect the same treatment for any undeclared UK income or assets.

Contraband, Cross Border Co-Operation and a result in the UAE

I came across this article (please click on headline) which I believe warrants a couple of minutes of your time.

1. It's a layering operation that has been spiked.
2. The warrant issued praised cross-border co-operation, Europe, US and UAE.
3. The arrest of 40 individuals in the UAE under the anti-money laundering. law for using hawala and money exchange routes for the illegal operation.
4. $4.3 million is still a lot of money.
   
   

It does look as if the change in political will in the Middle East that occurred sometime ago is now really starting to bear fruit.

Do you agree?

MEP's Block Whistleblower: Do you still want to be an MLRO?

In the world of Money Laundering Prevention there are good guys, bad guys and some really badly written laws in between.

Now the good guys tend to rely on clear controls, their personal ethics and their professionalism when examining the suitability systems and controls which should prevent money laundering and fraud. One of the key controls of last resort is whistleblowing.

People who are tempted to follow the accountant Marta Andreason’s (pictured) example of identifying inadequate controls that, in turn, permit fraud at the expense of the taxpayer to flourish should remember the following lessons.

§ Whistleblowers are not universally welcome.
§ Most whistleblowers will be subject to retribution by their employers.
§ Some management teams will be making too much money out of dubious activity to want to take any notice.
§ Where the law compels MLROs to become whistleblowers (e.g. UK’s Proceeds of Crime Act) on their own employers systems and controls, or wilful management complicity, they have probably ended their careers with that firm.
§ What a whistleblower may think of as an essential disclosure under public interest will probably be regarded as a leak by politicians (see House of Commons, public Administration Committee, Leaks and Whistleblowing in Whitehall, July 2009)
§ The recipient organisation of the disclosure may have absolutely no pastoral care systems put in place. In other words you are on your own with your family.
§ Politicians in particular dislike being reminded of their inadequacies.

Why do I include the last point? Well it is also the reason for including the picture. You may remember that Mrs Andreasen, was the European Commission's former chief accountant, was fired in 2004 after she publicly claimed there was a £172 million discrepancy between two sets of Brussels accounts.

According to the Telegraph, Lord Kinnock, who was then her boss as the Commission's vice-president, furiously accused her of "disloyalty and breach of trust" after she went to MEPs with her concerns, already raised internally, over accounting standards.

Mrs Andreasen was then elected as a Ukip MEP for South East England in June 2009.

Following on from her election, at the end of July 2009, Mrs Andreasen was blocked by Christian Democrat and Socialist MEPs from becoming vice-chairman of the European Parliament's budgetary committee on Monday.

The centre-Right European People's Party and the Socialists broke parliamentary convention on the allocation of committee posts by demanding a vote by secret ballot to block Mrs Andreasen.

Inge Graessle, a senior German Christian Democrat MEP, admitted that the former Commission accountant had been opposed for the senior post because of her trouble-making past.

"The role she played in the past, what I feel was a certain scandalising of issues, is not really one we want endorsed by her becoming vice-chairman," she said

Chris Davies, a Liberal Democrat, attacked the "shameful decision" to hold a secret ballot so the MEPs could not be "held accountable for their actions". The message it sends to the public is that anyone who speaks out against malpractice in Europe risks being excluded from office," he said.

To my mind, the conduct of MEP's is important in setting the tone of the debate around the prevention of financial crime. In this light, their recent behaviour has been utterly disgraceful.

Does their recent behaviour inspire trust in their integrity? Or is financial crime prevention something that Eurocrats only pay lip-service to?

What are your views?

China cracks billion-dollar money laundering gang

Associated Press have just reported that police in south China announced today that they had broken up a money laundering ring that sent $1.46 billion abroad in illegal transfers, mainly to Vietnam.

One of the ring's main suspects, a Chinese national named Ruan Zhizhong, allegedly opened 77 accounts and illegally transferred 7.2 billion yuan ($1.05 billion) through more than 10,000 transactions over a four-year period that ended in March of last year, Xinhua said.

Click on tile link for details.

Afghani Opium: Are vouchers the answer?

On the 8th August 2009, The Washington Post (The Post) published a useful article on Afghani Opium Poppy production, how it may link into the Taliban and what the US and UK Governments are trying to do about it.

The link is in the title above, but you may have to register with the paper in order to see it in full.

Here is the latest plan. Prior to the next planting season in October, the U.S. and British governments plan to spend millions of dollars to try to persuade Afghan farmers not to plant opium poppy. U.S. and British officials are hoping to provide alternative sources of legitimate income to what has been Afghanistan’s most profitable cash crop.

Opium is thought to be a major source of Taliban funding and official corruption.

Many poppy farmers survive Afghanistan's harsh winters on loans advanced by drug traffickers and their associates, repaid with the spring harvest. The two government s hope that by offering vouchers, selling wheat seeds and fruit saplings to farmers at token prices, offering cheap credit, and paying poppy-farm labourers to work on roads and irrigation ditches that they can when the farmers off their cash crop.

It can also be seen that the Bush administration's focus on crop eradication, which "wasted hundreds of millions of dollars," according to Richard C. Holbrooke, the Obama administration's special representative to Afghanistan and Pakistan ha failed. According to Mr Holbrooke destroying the crops succeeded only in "alienat[ing] poor farmers" and "driving people into the hands of the Taliban," he told reporters last week.

The Post notes, however, that many previous U.S.-funded crop-substitution programme s have failed as well, from Asia to Latin America. “A similar plan in Colombia, begun in the late 1990s, has barely made a dent in the level of cocaine production.”

It is also worth noting that the centre of the overlapping wars against opium production and the Taliban is southern Afghanistan's Helmand province, where more than two-thirds of the country's poppy is grown.

Most of you will know that this is where thousands of US Marines and British troops are in the midst of a major offensive there against entrenched insurgent forces and are providing security in villages as they are cleared.

"By this time next year," the senior military official said, "what we want to see is decreased poppy harvest. For us, that will be a metric of success. If we don't get conditions set now, in the next 60 days, we're not going to get the results we'd like."

But here comes the rub. The Post article goes onto report that according to Mr Holbrooke, most Taliban funding comes from wealthy individuals in the Persian Gulf region. Apparently there is also widespread agreement among U.S. officials that drug traffickers, warlords, corrupt government officials and insurgents work cooperatively to continue cultivation, processing of opium exports.

According to a United Nations report, the scale of the problem is huge:

§ More than 365,000 Afghan farm households earned about $730 m from poppies last year.

§ FYI, that amount is very nearly equal to the national government's $750 million in official revenue.

§ Both figures are dwarfed by the estimated $3.4 billion earned from opium exports.

According to the United Nations, "The average annual cash income of opium-poppy growing households in 2007 was 53 percent higher than those of non-opium poppy growing households," The U.N. 2008 Afghanistan Opium Survey also reported, "farmers in Helmand reported the highest cash income," 70 percent of which came from their poppies.

After production costs and local taxes, the average Helmand farmer (cultivating less than an acre of land) nets about $900. That is more than twice what he would earn from wheat at current, albeit rising, prices and assuming he has only planted approximately half his land with poppies.

Spring opium is harvested in May, after the plant flowers and seed capsules develop. The capsules are lanced and a latex-like opium gum oozes out and is gathered by hand. In Helmand, where production per acre is highest, opium poppy seed capsules are lanced on average of four times in a labour-intensive process.

Again the UN report quoted sheds valuable light on why this crop is so important in the Afghans way of life.

The average daily wage for unskilled labour is as follows:

§ For construction work it is $3.60.

§ Wheat harvesting earns $4.40, and

§ Opium "lancing/gum collection" pays $9.50.

§ Wages in Helmand for lancing, $15 a day, which are the highest in the country.


Now this blog aims to allow much greater communication. If anyone out there has any ideas as to how to constructively deal with the opium production issue, well I implore you to post them here and we can try and save a few lives!

Are our bank's now so target driven that they have completely lost the plot?

Chris Skinner's blog is a marvellous read and gives excellent examples of how technology and Web 2.0 can and should be used and how most financial services businesses just don't get it.

The post above being a wonderful demonstration of what is good for the bank can be appalling for it's clients.

How is Chris's experience relevant to Anti-Money Laundering? After all its not great KYC to disrupt your client's experience. Was this bank's behaviour driven by meeting sales targets on a certain kind of account (is this the dominant cultural theme?) or is it a cunning plan to delay a transaction whilst seeking consent (just kidding)?

Seriously, are the banks in the UK now so focused on how to make money out of their clients are they going to bothered with taking AML seriously?

It makes me wonder.

BBC's Peter Day Discusses On-Line Learning

Following on from my ramblings about money laundering training, the link above should take you the BBC podcast called "Learning Curve".

A very useful discussion of the history and uses of e-learning and how it may alter corporations going forward.

See Peter Day's written comments here: http://www.bbc.co.uk/radio4/features/in-business/peter-days-comment/20090730/

HMRC Announce Short Consultation Period on MLR Fees

Dear All,

HMRC's Money Laundering Regulations (MLR) team have today announced a review of the fee charging structure .

They will be contacting AML regulators and over 2,000 businesses, asking for your views on:

• the current fee structure
• possible alternative fee structures
• how the annual fee should be spent
• This is an opportunity for you to let them know your views on MLR and what does and doesn't work for you.

If you are a business regulated by HMRC you will either receive a questionnaire in the post, or follow the link and download it yourself. Please note, however, the short time frame of this exercise. The questionnaire will only be available until 15 September 2009.
Go to the online fee review questionnaire.

HMRC warns of ‘real risk’ from scam emails

Recently scam emails promising a a tax refund have been sent out by scammers. This Activity has been increasing during 2009 and recipients are requested to enter bank and credit card details for repayments to be made. The HMRC have warned that some of the fraud attempts are quite plausible.

The following press release is quoted in full so that everyone knows what is going on. The link in the title takes you to the relevant HMRC website and was posted on 22nd July 2009.

Criminal gangs are targeting taxpayers with thousands of scam emails offering bogus tax refunds. The online attacks, known as ‘phishing’, have peaked during July leading to increased reports of fraud to HM Revenue & Customs (HMRC).

The scams tell the recipient they are due a tax refund and ask for bank or credit card details so that the fictitious tax refund can be paid out. HMRC is warning customers about the possible dangers of falling for this scam during this phase of increased attacks on UK residents.
All customers who provide their details to the fraudsters run a real risk of their accounts being emptied and credit cards used to their limit. The victim also risks having their personal details sold on to other organised criminal gangs.

Lesley Strathie, HMRC Chief Executive said:
“We only ever contact customers who are due a refund in writing by post. We never use emails, telephone calls or external companies in these circumstances. I would strongly encourage anyone receiving such an email to immediately send it to us for investigation and delete it from their computer.”

HMRC is taking action to disrupt these attacks and through co-operation with other law enforcement agencies in the UK and overseas a number of scam networks have been shut down – most recently in July in Korea, Thailand, UK and USA.

HMRC strongly advises: * Check the advice published to hmrc.gov.uk/security/index.htm to see if the email you have received is listed.

* Forward suspicious email to HMRC at phishing@hmrc.gsi.gov.uk and then delete it from your computer / mail account.
* Do not click on websites links contained in suspicious emails or open attachments.
* Follow advice from http://www.getsafeonline.co.uk/. If you have reason to believe that you have been the victim of an email scam, report the matter to your bank/card issuer as soon as possible.
* If in doubt, please check it out with HMRC at http://www.hmrc.gov.uk/security/fraud-attempts.htm


Notes to editors
1. The scam email often begins with a sentence such as ‘Following a review of your fiscal activity you are due a refund of tax of £XXX.’ 2. HMRC previously warned the public about phishing attacks in January 2009 during the run-up to the deadline for online self-assessment tax returns. 3. The current increase in scam emails is partly due to people following HMRC advice and forwarding them to the department’s security and fraud team.4. In the last 12 months HMRC has received over 15,000 reports of fraudulent repayment emails.5. Do not visit the website contained within the email or disclose any personal or payment information.
Email addresses used to distribute the tax rebate emails include:
* refundtax@hmrc.gov.co.uk
* TaxRefund@hmrc.gov.uk
* service@hmrc.gsi.gov.uk
* claims@hmrc.direct.gov.uk
* notice@hmrc.gov.uk
* hmrc@hmrc.gov.uk
* admin@hmrc.gsi.gov.uk
* info@hmrc.gsi.gov.uk
* no-reply@hmrc.gsi.gov.uk

HMRC does not send out emails using these email addresses.
Issued by HM Revenue & Customs Press OfficePress enquiries only please contact:
Contacts

NDS Enquiries ndsenquiries@coi.gsi.gov.uk

Money Laundering in action: Mixed views about this one..

This is a January 2008 story, originally shown as part of the BBC's CrimeWatch programme. So it is not fresh but it encapsulates nicely how:

1. Money Launderers don't care if you or your firm is regulated for AML purposes, they will just use you.


2. Transaction costs are of little consequence to Money Launderers.
   
3. Money Launderers ability to use your own systems against you (in this case ticket machines).


4. I've mixed views about this because although what they are doing is obviously a crime and they should be stopped, it does seem to be that they targeted some of the companies that I've commuted with! Sympathetic to the plight of these companies, I am afraid I am not.

"CCTV shows a large-scale money laundering scam taking place at train stations in south London, Surrey and Kent. Several suspects have been caught on camera using ticket machines to get rid of dyed/damaged notes stolen during cash-in-transit robberies. They select the cheapest fare, pay with a stolen note and then pocket the change. The scam is believed to have resulted in around £60,000 worth of notes being pushed through the machines in the last four months."

For CCTV footage of the people police want to talk to in connection with money laundering in London, Surrey and Kent, please follow this link :
http://www.bbc.co.uk/crimewatch/appeals/2009/02/train_station_money_laundering.shtml

Crime date: 19 January 2008
Nature of crime: Money laundering
Where: Train stations, London, South East
Contact: British Transport Police
Phone: 0800 405040

Some thoughts on AML training

Hi All,

I've just posted the response below to a question on annual AML training that was posed in the Compliance Professionals - Saudi Arabia discussion forum on LinkedIn. So thanks to Naji Osman for his gracious permission to cross post this.

The key point that I wanted to get across is that the there is no one correct answer to the conundrum of what is best practice in AML training, rather it should be what works for your organisation!

Your feedback on my views is welcome.

"If I could take this training question from different point of view (pov) say from a senior management pov, an MLRO's pov, a back office and a front office pov all of which are subtly different, although occasionally aligned.

Senior Management want to know whether the training undertaken is effective in complying with the regulatory expectations of the firm without being an unnecessary burden to the bottom line, in other words do we comply? They like to try and master what they see are the key risks to the firm, what can be done to manage the immediate higher risks within existing resources, what risks need to be covered by new resources (additional staff, new computer system etc) and what can be delayed and put into a project management tool and what they can safely ignore.

An MLRO tends to want to prove that all or all relevant staff have been trained that year and that they understand what the training is trying to do for them, see Naji’s excellent points about Accounts and understanding what it means for their day to day job. MLROs will also tend to deliver the training (professional development) to their own senior staff so that they can be sure what key concerns senior managers may have. Now an MLRO might also try and establish a common approach from the Board (if possible) so that a common culture of what is expected from people in the business can be established. A useful but difficult aim to achieve sometimes.

Back Office tends towards looking at how this training will be relevant to them and how it will affect their current systems. By way of an unscientific observation, they tend to look on face to face good quality training as a perk and they tend to more easily grasp some of the more unpleasant what if scenarios that AML training can generate. Some of the best SAR’s I have seen generated have come from back office staffs that have picked up expected third party payments, unexpected currency settlements etc.

From Front Office (here follows a massive generalisation) its does this stop me earning money? If it does can I shovel the responsibility elsewhere eg to client on boarding for KYC completion etc. If a firm wide culture has o not been established (with senior management on board) this is where you can run into some resistance if you are not careful.

Re types of training, for large complex firms Computer Based Annual Training is the only sure way of establishing and proving through effective audit trails that AML training has been done. It is also very easy to introduce annual competence tests built on questions answered correctly. Advantage is that is transparent easy to monitor and can be update in a uniform way. It is easy to repeat annually.

Disadvantages can be:
 high degree of initial cost in ensure content is relevant to a firm’s actual activities and AML risks,
 People can pass with strong marks but fail to understand what the training is telling them.
 DVD’s aimed at banks don’t go down well with Asset Managers.
 Can be expensive to refresh to keep it relevant as the firm and the markets that they operate in change.

Re bespoke face to face training the advantages tend to be:
1. High degree of relevance to the firm and the particular group you are training
2. A greater degree of interactivity with, if your trainer has the right experience, the ability to answer the vast majority of questions raised there and then.
3. Should be easy to incorporate relevant developments over the last 12 months.
4. If repeated annually you develop a greater degree of trust which enable she delivery of more challenging / demanding AML requirements over time. E.g. With a number of my clients they now look forward to their annual training and they no discuss some very sensitive issue from an AML compliance pov in a way they didn’t say 2 years ago.
5. If you mix in senior management, back office front office into different groups and the MLRO attends all the training, some of the discussions are a real eye opener.

Tip to my mind, the mark of a good trainer that has got the message trough is that the firm’s MLRO will find that they receive a greater number of queries and questions / phone calls from their colleagues following the training discussing AML risks. If your trainer is delivering this you may want to consider why not.

Disadvantages;
 Cost per head can be prohibitive.
 Proving that trainees have reached sufficient level of competence i.e., some of the training would probably be devoted to tests
 Some people don’t do well in face to face training and are better with PC based.
 Senior Management sometimes do not want to show their firm members what they do and don’t know.


Some firms now use a combination of both types of training (e.g. I’ve written CPD content for some firms whilst supplementing it with selected high level training for senior managers before role out) others favour one over the other."

Kafkaesque Terrorist Freezing Orders, The UK Treasury Way

Many of my training clients will know that I tend to bang on about the risk to the AML regulated sector posed by HM Treasury's (HMT) liberal use of Statutory Instruments to fight terrorism and serous organised crime.

Little did I know that this Labour Government would prove my cynicism right in spades.

Below, you'll find below a copy of the Channel 4 News item first aired on 23rd March 2009.

In it one man known as 'Q' tells how his life was ruined after the government froze his bank account under the UK's terror laws. HMT Treasury can and do impose this Kafkaesque regime on anyone it suspects of funding terrorism

Under laws that the Treasury wrote, it doesn't have to bother about bringing charges, or even informing the subject of the order what the nature of the allegations are.

Under these orders, your bank accounts and all your assets are frozen and you need ministerial approval to buy a pair of shoes. You cannot undertake any financial transactions - making it virtually impossible, in the interviewers opinion to work.

In the interview with Channel 4 news, one man known as 'Q' says his life has been ruined after he was blacklisted without ever knowing why.

May I suggest that you pay close attention to Dominic Grieve's contribution toward the very end of the video (6:16).



Despite this "proportionate" behaviour going on, HMT still appear to be living in cloud cuckoo land. At a counter terrorist conference I attended in July in London, it became abundantly clear that once anyone had come out of this terrorist blacklisting, the regulated financial sector was expected to give the victim of this order full access to all financial services.

Taking a risk based approach, mindful of the fact that some one is publicly labelled as possibly financing terrorism, that this listing has been based on most secret Government information (which they are certainly not going to share with the regulated institutions / firms)and that the Governments action may actually have radicalised the subject of the order, no institution in it's right mind would touch that person with a barge pole. Well not unless the Treasury was to indemnify the AML regulated firm against all future acts by this person in perpetuity.