The Dark Money Files: Recent Episodes
Graham Barrow and Ray Blake
A series of podcasts which explain to a non-technical audience how "Dark Money" (e.g. money laundering, corruption, bribery, tax evasion) enters the financial system and infects everything it touches.
In a slightly longer than normal episode we do a deep dive into partnerships of various flavours and how the Economic Crime and Corporate Transparency Act is going to change things.
Partnerships are not straightforward (hence the longer episode) but they are sensitive to abuse so this is an important topic for financial crime professionals.
And there is the offer of a free gift at the end of the episode!
What's not to like.
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We take a look at the effect of human behaviour on our ability to stop criminals gaining access to the financial system and why that system is more likely to produce comprehensive documents than effective detection.
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We look at the role of Authorised Corporate Service Providers (ACSPs) in the new regime at Companies House and explain why understanding both its strengths and weaknesses is important to anyone responsible for onboarding or monitoring UK companies, wherever in the world you work.
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One for the geeks!
Changes in company formation levels are often use to justify/criticise different governments' economic policies.
We go behind the headline figures to see if this is justified or not (HINT: not!).
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Ten years after the creation of the Office of Financial Sanctions Implementation, we look at how the UK sanctions regime has evolved—from early uncertainty to strict liability enforcement, sanctions list complexity, and the growing expectations on the private sector.
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Today we tackle some colourful risk lists or, to be a bit more precise, some black and grey ones, along with some strange differentials.
Like how come the UK has a high risk third country list when there are no second countries in sight?
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In the second of a two part, end of year podcast, we continue to explain how we helped with a major BBC investigation into crime on the high street, involving the sale of illicit cigarettes and vapes, modern human slavery, people trafficking, tax evasion, corruption and money laundering.
In this episode, undercover filming unearths a shocking story and we explain our part in finding some of the protagonists involved.
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In the first of a two part, end of year episode, we explain how we helped with a major BBC investigation into crime on the high street, involving the sale of illicit cigarettes and vapes, modern human slavery, people trafficking, tax evasion, corruption and money laundering.
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We examine two recent final notices issued by two different regulators relating to two quite different enterprises and find a surprising amount of commonality in their thinking.
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In the first of a new, occasional series, in which we sit down and chat to fellow anti-financial crime professionals, we kick off with Marit Rødevand from Strise to talk about AI and other new fangled gizmos.
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The UK Insolvency Service does a lot more than just oversee insolvencies and, in a recently published five year strategy document, they outlined some ambitious future goals which we thought were well worth a conversation.
So we had one!
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The FCA recently published new guidance specifically in relation to UK PEPs which we decided needed a closer look. So we did!
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In this episode we explain how we supported a major BBC investigation into a Hungarian organised crime group which was systematically forging wills and stealing the assets belonging to the estate from under the noses of the true beneficiaries.
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In this episode, we chat about a recently published report by Transparency International (see: https://www.transparency.org.uk/news/trust-issues-tackling-final-frontier-secret-property-ownership) and how it impacts on our ability to identify the true ownership of real estate in the UK (and elsewhere).
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We bring you our latest deep dive into the world of crazy company incorporations and weird worldwide coincidences by way of North London, New Zealand and a much loved British sit-com.
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SARs!
Search and rescue services?
Subject access requests?
Sudden acute respiratory syndrome?
No - suspicious activity reports! That's what we are talking about this time. And there's a lot more to them than you might think.
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In this episode we look at the FCA's latest thematic review of the National Fraud Database and money mule account detection tools and summarise what we think firms can take from it and what actions they might consider taking in response.
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"...Because every day we pay the price, we’re the living sacrifice"
Taking inspiration from Bob Marley (sorry about the pun) we've done a little episode about scams and scammers (and some hints on how to spot them).
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In this episode we look at some of the links between three recent enforcement actions.
We try to avoid the knee jerk reactions, and think a bit deeper about them.
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We turn our attention to the requirement to train relevant staff on all matters anti-financial crime.
And if you're planning on training - your training needs a plan!
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In this episode we turn our attention to the tricky subject of outsourcing. We were going to get someone else to do it for us but we couldn't find a suitable candidate. :)
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Hot spots and intelligence 2
In this second episode we look more broadly at the genesis of intelligence led policing, how it works and how compelling it is to draw parallels with our world of anti-financial crime.
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In this episode we report on a recent visit to the European Crime Analysis conference in Copenhagen and draw parallels between the work of law enforcement and those working in compliance.
Links referred to in the episode:
Hot spot policing
Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity
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In this episode we explore some of the many different ways in which corporate entities can be used to engage in financial crime – although, as far as we are aware, they aren’t much use in removing stones from horse’s hooves.
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We dive into the details of OCGs and how they use corporate networks to launder their ill-gotten gains - and the clues they leave behind.
And, rather appropriately, we also introduce the world to our new sponsor: https://riskalert247.com/
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In this episode we turn our attention to the thorny subject of proliferation financing and provide a basic explainer of what it's about and why it's important.
The documents referred to in the episode can be accessed via the links below:
FATF Guidance on PF risk assessment | https://bit.ly/4a9FKTM
UK National Risk Assessment of PF | https://bit.ly/3JP2Lk7
| RUSI paper on PF in banking | https://bit.ly/4b4JpTU
| European Commission guidance for EU operators | https://bit.ly/4doVhSr
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With a forthcoming new requirement which makes it mandatory for UK payment service providers (PSPs) to reimburse the victims of some types of fraud, we look at the rules and how they are likely to play out.
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Taking a slightly different direction from our normal content, we step back and look how the landscape of crime has changed over the years, and how in the process it has become democratised.
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Following the news that nearly 800 restaurants in the UK have been cloned over the last few weeks, we thought we’d bring you the story behind the story.
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It’s over to EU
After a succession of episodes looking at the UK financial crime landscape, we shift our focus over the channel to Europe and the proposed changes to EU AML legislation.
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Following some recent banking shenanigans, there’s been a rapidly introduced change in the UK law relating to PEPs.
We think it needs to be put into a global context.
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In this second part of our review of the Economic Crime and Corporate Transparency Act, we look at the provisions relating to failing to prevent fraud, crypto assets, information sharing and Strategic Lawsuits Against Public Participation (SLAPPs).
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Following the enactment of the Economic Crime and Corporate Transparency Act, reform is on the way to Companies House.
But what does it look like and when will it happen?
Here's our initial overview.
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In this episode we walk the path from certainty to impossibility, via probable, possible and plausible.
A conversation involving wind turbines, zebras and UFOs.
You need to listen to understand!
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In this second episode devoted to ultimate beneficial ownership, we delve into the world of exchange traded companies and the esoterica that is trusts.
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In this episode we, somewhat belatedly, begin to tackle the thorny issue of identifying ultimate beneficial ownership.
And we do so by pointing out that the “ownership” part of UBO is a bit misleading because it doesn’t cover control or influence.
But then a UBOCI is a bit of a mouthful.
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In this episode we walk through a recent, in-depth report into probable VAT and employment tax fraud reported on by Dan Neidle of the Tax Policy Associates, in partiucalr, how various different proessionals, individuals both here and abroad, and social media websites can be used, wittingly or unwittingly, to further the fraudsters aims.
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We couldn't let the recent Farage brouhaha with Coutts go by without some sort of comment.
We've tried to chart a calm course through some choppy waters!
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In this episode we ask "What have the dinosaurs ever done for us?"
It turns out, if you ask the right questions, it's quite a lot.
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In this episode we take a (hopefully) user-friendly trip down the statistical road and explore some of the common pitfalls that can be encountered in preparing management information.
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In this episode we look at the thorny issue of Management Information. What is it and what’s it for.
Simple questions you might think, but often overlooked.
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In this episode we bring you an update about regulatory expectations in respect of cash deposits.
Along with a brief history of the UK’s Post Office dating back to the 17th century and the somewhat surprising news that it is still possible to make unlimited daily cash deposits of up to £20,000 with no form of identification.
More information on KURE (brought to you by our sponsors Deep PoolmLtd) can be found at www.deep-pool.com.
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In the first episode of season 10, we turn our attention to an extraordinary story about online retail sales, China, VAT and HMRC.
Despite all the apparent jargon, it is just an everyday tale of 11,000 companies all suddenly deciding to register to a private address where the owner had never heard of them.
Which didn’t stop him being sent £500,000 in debt enforcement letters.
And, in a first for The Dark Money Files, this podcast is now sponsored which will secure the ongoing future of the podcast and ensure we can continue to deliver a quality product.
Here’s a link to our sponsor’s website: https://www.deep-pool.com/
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In the second part of our look at multiple choice tests we talk about how some fairly basic statistical analysis can help to validate their effectiveness.
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Does your assessment programme correlate to individual performance?
And if not, why not?
Part one of a journey on the road to cognition.
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In this episode we talk about using our (metaphorical) little yellow bird as a predictor of the overall effectiveness (or lack of it) of your anti-financial crime framework.
Would your KYC fall off its perch at the first whiff of trouble?
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In this episode we work through three of the smaller regulatory actions from last year which nevertheless contain nuggets of gold, successfully panned by Ray.
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In something of a departure from our normal content, we review the passage of the Economic Crime and Corporate Reform Bill through the UK parliamentary system and use the opportunity to explain in more detail just how the scrutiny and passing of legislation works in practice.
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In this episode we weave together crypto, courts and controversy when Sam Bankman Fried meets the Court of Justice of the European Union and a millionaire underwear Baroness.
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It’s been a little while so we thought we’d do a bit of a catch up on some recent publications from Wolfsberg, the FATF and the Finnish FSA.
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In our final part of our look at fraud, we explain, in general terms, current approaches to how best to compensate the victims and deny the fraudsters (as well as explaining briefly, why the gap since the last episode).
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We interrupt our suite of podcasts on fraud to bring you a special episode relating to the human cost of fake company incorporations.
Working with various different media outlets, we’ve helped bring to light some of the stories relating to people who unwittingly fall foul of fake company incorporators.
Listen, for example, to this recent episode of BBCs You and Yours:
https://www.bbc.co.uk/programmes/m0019z2g
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In this second part of our series on fraud we delve into some of the different types of fraud.
We proffer some “mildly salacious” examples, along with others which are rather more serious.
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In this pun laden episode, we start to delve into the world of fraud. More to follow…
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The UK regulator, in common with most regulators around the world, is keen to understand the role that synthetic data might play, alongside Artificial Intelligence and Machine Learning.
It has made a call for input which closes on 22 June.
In this episode we review the current state of play, the uses for synthetic data and why contributing to this call is so important.
Link to the call: https://www.fca.org.uk/publication/call-for-input/synthetic-data-to-support-financial-services-innovation.pdf
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In this episode we tackle the thorny issue of tax avoidance, aggressive tax avoidance and tax evasion. We also take a closer look at one of the schemes which falls somewhere on that spectrum: mini-umbrella companies.
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In this episode we look at all things digital and how it is changing the landscape of authentication whilst making KYC more dynamic.
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To conclude this trilogy of podcasts looking at the world from the money launderers point of view, Ray and Graham take a deep dive into trade-based money laundering and trade finance.
They revisit the research conducted by John Zdanowicz – copy of the report referred to can be found here.
$5000 tweezers and enriched uranium at $15/kg make for a lively episode!
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In this second part of Graham & Ray’s trip to the dark side, and with almost prescient timing, they explain how to set up a global money laundering machine.
Please don’t try this at home.
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Having spent three years and 93 episodes reporting from the side of the great and the good, Ray and Graham move the focus to the view from the dark side.
And it sounds like they had an inordinate amount of fun doing so!
Two more parts to follow!
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We bring this trilogy of episodes around transaction monitoring failures to an end with a final review of the NatWest case and a comparison with the recent fine levied against HSBC.
What’s that got to do with a King, his cleaner and a thirsty aspidistra? You’ll need to listen to find out!
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In this episode we bring you the second part of our deep dive into the criminal prosecution of NatWest through the lens of the Statement of Facts which accompanied the guilty verdict.
This time, amongst other things, we cover smelly banknotes and bin bags full of cash.
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In this episode we bring you part one of a deep dive into the criminal prosecution of NatWest
through the lens of the Statement of Facts which accompanied the guilty verdict.
No matter where you are in the world, given the ubiquity of AML regulations, this will be relevant to you and your organisation.
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In this episode we want to move away from always being suspicious and look at the other side of the coin. Can we use green flags to help identify suspicious behaviour from a very different angle?
And do we need to be cautious in our use of whitelists?
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In this episode we enthusiastically review the new advanced search function recently launched on the Companies House website. We also make a heartfelt plea for other corporate registers to look and learn from the huge potential gains in proactively managing corporate financial crime risk that it facilitates.
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In this episode we look at how the FCA’s REP-CRIM report can assist firms in assessing the effectiveness of their AML controls through both trend analysis and benchmarking against their peers. And we explain how trend analysis such as this can benefit all financial institutions wherever they do business.
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In this episode we review the need for firms to review, and adjust as necessary, their financial crime control environment. We also talk about some of the triggers which might cause these adjustments and the actions which might follow.
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In this episode we give our views on the Pandora Papers and some of the broader considerations which might flow from their release.
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Remediation programmes are becoming an all too frequent feature of life for financial crime compliance departments, so we we’ve put together a summary of good practice, do’s and don’ts and other things to consider when embarking on such a course of action.
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Sometimes you just have to go back to basics. And this week it's risk.
Does low risk equal no risk? Is all risk equal? Should you ever do EDD on a low risk customer?
We answer these questions and many more.
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In this episode we wander away from traditional banking intro the world of informal value transfer systems. Oh, and we look at the price of missile launchers. But you’ll need to listen to understand why!
Link to the TBML paper written by John Zdanowicz
https://www.researchgate.net/profile/John-Zdanowicz/publication/46556338_Trade-Based_Money_Laundering_and_Terrorist_Financing/links/02e7e534489c545100000000/Trade-Based-Money-Laundering-and-Terrorist-Financing.pdf?origin=publication_detail
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Occasionally, we record an episode which is truly an exclusive, and this is one of them.
This episode started life as a straightforward explanation of the use of art and auctions in money laundering schemes. And then it went off on the most unexpected and jaw dropping tangent. You’ll need to listen to understand how art, auctions, sanctions and shell companies relate to the explosion in Beirut and the world of money laundering.
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This is just a very quick episode to let everyone know about the upcoming Dark Money Conference. It's online so it doesn't matter where in the world you are and it' going to be great! link to the website: https://darkmoneyconf.com/
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We interrupt our series on Alternative Laundries to review the recent FCA Dear CEO AML letter which, whilst aimed squarely at UK financial institutions, will have relevance across the world, especially where those global banks have UK retail operations.
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In the second part of our Alternative Laundries series, and against all the odds, we turn our attention to casinos and gambling. It's a big deal!
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In this episode, we dive into the world of alternative money laundering methodologies, starting with lending and insurance. And we find out that, with a bit of imagination, any store of value can be used to launder money - sometimes in surprising ways!
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Following the news that the FBI and Australian Federal Police had managed to seed a bogus “encryption device” into a huge global network of organised criminal gangs, followed by an equally global set of raids, arrests and asset seizures, we review what we know, alongside the recent Encrochat hack and surmise what this might mean in the fight against global organised crime.
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In this episode we talk all things FIU along with the history and role of the Egmont Group. We discover the different flavours of FIU and how they work with the other elements of government and the law.
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In this episode we look at the role of critical thinking in the world of Financial Crime Compliance. What it is, how it works and some examples of critical thinking in practice.
And we conclude that it is one of the most important skills necessary for effective risk management.
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With the breaking news that ABN AMRO have been fined just under €500m and three former executives are currently subject to a criminal investigation, we draw out the main themes emerging from the report.
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In this episode we talk about the recent criminal charges brought against NatWest Bank and liken the underlying issues to boiling a frog. Of course.
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In this week’s episode we deconstruct a recent paper from the.United Nations Office on Drugs and Crime which defined what is meant by an illicit financial flow and which proposed a statistical framework for reporting on them.
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In this episode, we look at the newly enacted Corporate Transparency Act, specifically in relation to the new beneficial ownership requirements in the US, how they will work, who is affected and areas for improvement.
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The massive explosion in Beirut. Sanctioned individuals. Dangerous chemicals. UK shell companies. ISIS. Russia. Syria. What connects them all?
We do.
There is an accompanying article on The Dark Money Files LinkedIn page.
In the fourth and final part of our review of the year we talk about Woolly Rhinos, Chang'e 5 and Panto Dames. Recombinant vector vaccines, Edward Snowden and Dread Pirate Roberts. Plus we chuck in a quick review of the Egyptian dynastic period and life (or not) on Venus.
What's not to like!
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In a highly alliterative third part of our review of the year we talk about Jumbo Jets, Mexican Mammoths, PP Tapes, Kim and Kanye, the Beirut Blast, Dangerous Drugs and Strange Stars.
Join us for a meander through some of the well known (and less well known) stories from the summer of 2020.
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Following rapidly on the heels of Part One, we bring you part two of our review of the year. This time we chat about news stories from April to June including Kim Jon Un, David icke, Elon Musk and Dad's Army . But not necessarily in that order. Or in any order, really.
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In a complete departure from our normal podcast we bring you part one of an unscripted conversation between Ray and Graham, looking back at some of the major news stories of the year (noting to do with financial crime).
In this first part we cover January to March.
Please be aware, we are unashamedly open about our own beliefs which not everyone will agree with and that's OK. What we didn't want to bring you was some anodyne claptrap designed not offend no-one but which also says nothing of interest.
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Following hard on the heels of the FinCEN files, the UK has just published its review of the SARs filed in 2019 which gives us the opportunity to look in detail at the headline figures and chat about SARs (both Money Laundering and Terrorist Financing) in a bit more depth.
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At long last (some may say) we look at various types of sanctions, the people or entities to whom they may be applicable, and the main issuers of sanctions lists, explaining (at a high level) how they work and what financial institutions need to do.
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In this episode we look at Unexplained Wealth Orders (UWOs) - explaining the law, how they are obtained, who they are obtained against and some of the initial uses to which they have been put.
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In this episode we look at (and broadly welcome) the proposed reforms to Companies House - an issue which matters globally given the ubiquity of UK entities in global money laundering schemes.
Our reservations - budget and timetable (plus a few more technical quibbles)
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Following our hugely successful Dark Money Conference in association with fscom, Ray and Graham take a bit of time out to look back at the highlights and draw out some of the compelling themes that emerged.
They also announce how those who were unable to attend can get access to all of the content and the associated masterclasses as well!
For tickets, please visit our website at https://www.thedarkmoneyfiles.com/ and follow the links for "post event access".
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Following the release of the #FinCENFiles and the involvement of The Dark Money Files in the story, we have recorded our longest and most in depth episode ever, looking at what it all means.
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In advance of our online conference at the end of September, we review, the speakers, the panels. the subjects and the additional content that subscribers will receive for their very modest outlay.
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In this episode we review the recent guidance issued by the UKs tax regulator (HMRC) for the benefit of Trust and Corporate Services providers. Amongst other things, it provides a very clear and articulate statement of some of the red flags to watch out for (along with a lot of abbreviations).
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We're back for Season 5!
We begin with a look at the new Wolfsberg guidance around Source of Wealth (SoW) and Source of Funds (SoF). Whilst we're broadly very supportive, there are a couple of elements about which we're not quite so enthusiastic.
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The third part of our look at the Consent Order issued by the DFS NY against Deutsche Bank throws up some worrying inconsistencies between the CO and the Bruun & Hjejle Danske bank report. Was it because Danske Head office didn't know, they did but didn't disclose to B&H or they did disclose and it was withheld from the final report?
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In part two of our special report into the Consent Order issued by the DFS NY against Deutsche Bank we look at its troubled relationship with FBME, the Cyprus based subsidiary of the Federal Bank of Lebanon and conclude that being a correspondent brings with it ethical issues that are not always there with direct client relationships.
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In the first of a trilogy of special episodes relating to the recent Consent Order agreed between Deutsche Bank and the Department of Financial Services - New York, we look in detail at the nature of the relationship, and the mistakes that were made, when Deutsche Bank decided to do business with Jeffrey Epstein.
Some of which (surprisingly) has either not been reported or only reported in passing.
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In this second part of our review of recent fines against SEB in Sweden and Commerzbank in the UK we dive into the detail of the Commerzbank Final Notice which reveals one or two surprises!
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In this episode we begin our review of the Commerzbank fine by the FCA and give a brief overview of the SEB fine by the Swedish FSA. What can we learn from these events?
Have a listen to find out!
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In this episode we review the recent report by David Leask and Richard Smith published on the OpenDemocracy website revealing the current state of play with respect to the UK Person with Significant Control regime. We use the opportunity to summarise the reasons for, and the requirements of the regime.
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In this episode we cover the foundations of trade based money laundering, what it is and how, classically, it is done. Along the way we make some surprising price discoveries on Amazon, compare a pair of tweezers to the size of a hydrogen atom and discover an unlikely candidate for dual use goods.
Link to the John Zdanowicz TBML research: https://www.researchgate.net/publication/46556338_Trade-Based_Money_Laundering_and_Terrorist_Financing
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This week we look at the impact of the coronavirus on bank's financial crime controls, processes and systems. We also give an update on the Dark Money Files Conference which is still going ahead as planned in September, although in a different format!
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Part two of a two part episode reviewing and commenting on the recommendations contained in the recent European Banking Federation's review of the role that banks need to play in the fight against dark money.
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Part one of a two part episode reviewing and commenting on the recommendations contained in the recent European Banking Federation's review of the role that the banks need to play in the fight against dark money.
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A short episode announcing the birth of "The Dark Money Files Live Online". We're just finalising the right platform, material and timings and subscriptions will open shortly.
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Following the release of the Clifford Chance report into Swedbank's High Risk Non Resident portfolio (HRNR) in the Baltic States, we have recorded a special episode based on our initial review of the Executive Summary of the report.
In our opinion it mostly makes for "ugly reading".
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In this episode we return to the theme of effectiveness, stick up for Deutsche Bank, prefer the Avengers over Batman and announce our forthcoming Dark Money Conference.
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In this episode we look at the effectiveness of AML control frameworks, what we might mean by effectiveness, the use of fines and the onset of compassion fatigue,
We also announce the forthcoming Dark Money Conference about which we will be saying more in our next episode.
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In what is probably the most important episode we've recorded to date, we talk about the way in which money laundering is reported and the potentially sexist narrative that underpins it.
We also talk about how the frame of reference which the general public forms in relation to money laundering can be altered (for better or worse) by the manner of that reporting.
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In this episode we look at the recent proposed defamation case between Javanshir Feyziyev and the OCCRP and the role that The Dark Money Files played (so far as we are able to talk about it) in the lead up to the case (which never actually went ahead).
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In this special episode to launch Season 4 we look at the newly revamped FCA - Financial Crime Guide and decide that it is an invaluable tool for financial crime professionals wherever in the world they might work.
We also take a look at confirmation bias and how it can contribute to less than effective outcomes.
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In this last episode of season 3 we turn our attention to conducting the business (or enterprise) wide risk assessment. Why and how figure prominently.
We also look at the main elements of the soon to be introduced (as at 08/10/2020) Money Laundering and Terrorist Financing (Amendments) Regulations 2019.
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In this second part of assessing customer risk, we look at the impact of delivery channel, products, entity type and industry on the overall risk rating. We talk about the changes that new technology have had on verification of ID and how different firms need to tailor their risk assessment to their own product and demographic range prior to addressing the firm wide risk assessment in our next episode.
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This week, after a brief review of the latest OCCRP stories (called #29leaks) we turn our attention to the thorny issue of customer risk assessments, starting with a focus on country or jurisdictional risk.
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We take a close look at events reported by SVT (Swedish Television) in relation to SEB's non-resident banking in the Baltics.
Based on leaked material which has been shared with us, we include a forensic review of the detailed statement carried on their website and conclude that their are areas which still leave room for concern.
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In this episode we complete our look at PEPs by going into Enhanced Due Diligence in a bit more detail before turning our attention to other high risk situations.
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In this episode we talk all things PEP. We cover how to define one, what constitutes a relative or close associate, what is the difference between source of wealth and source of funds and the thorny issue of PEP retirement or declassification.
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In this episode we look back at a recent episode of the BBC1 news programme "Panorama" featuring drug money, gold bullion, billions of dollars of money laundering, poor treatment of whistle-blowers and a (very brief) appearance from one half of the duo.
We talk about the money laundering "process" and how the description could be improved and look ahead to a forthcoming mini-series on "risk" starting with an introduction to the world of Politically Exposed Persons (PEPs).
We also announce the launch of our YouTube channel (https://www.youtube.com/channel/UCxQt-hM8EsoV-xLufUtY8Vw) and a significant upgrade to our website (https://thedarkmoneyfiles.com/) as well as a new "The Dark Money Files" venture - a "Serial" type podcast reporting on a detailed investigation in-depth. Due to launch in the New Year, the first season is provisionally titled "The Tower".
This week we look at two separate issues (but there are similarities).
First up, Swedbank published its 3rd quarter results this week and included an update on their ongoing investigations into the alleged use of their bank as part of a money laundering operation in the Baltics.
Secondly, we revisit the recent FATF plenary in Paris and put forward our own proposals for how we think the Mutual Evaluation Report process could be improved.
Both demand to be looked at as much in the round as they do in detail.
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This week, in honour of the first 2019 Plenary meeting of the FATF we look at the birth of the organisation in Paris in 1989 and a pillar of its existence - The Mutual Evaluation Report.
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In this episode we look at the recent raid on Deutsche Bank in connection with the Danske Bank story, the role of correspondent banking in the story and the risks associated with it.
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In this episode we take a long hard look at the reporting requirements and all the other responsibilities placed on the Money Laundering Reporting Officer.
We look at an example of what can happen when thing go wrong but also the huge variety of challenging but interesting and important jobs the MLRO is responsible for.
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In this episode we reflect on some past episodes, chat about the recent Dark Money Files Live event and announce some exciting news for followers of the podcast.
New ways to bring you Dark Money stories!
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In this first episode of season three we give our listeners an overview of the report to the EU Parliament and Commission looking at recent money laundering cases in Europe and what we can learn from them.
In this final episode of the Deutsche Bank story we look at the acquisition of Morgan Grenfell and Bankers Trust along with the banks somewhat strange relationship with Donald Trump. We also mention "The Dark Money Files Live" event which is coming soon to a location in London (with others to follow, we hope.
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In this episode we complete our review of Deutsche Bank's inspection by the FCA which led to them being fined £163m (and $425m by the Department of Financial Services - New York). W explain in some detail all of the areas identified for criticism but also highlight some of the good things Deutsche Bank did which don't always get the publicity they deserve.
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In this second part of our in-depth review of the recent travails at Deutsche Bank we talk about the background to the Systematic AML Programme (SAMLP) visit by the FCA, the LIBOR fine which preceded it (including the £100m fine for DB's breach of Principle 11) as well as describing what exactly a SAMLP entails.
Whilst this is specifically a tool in the UK regulator's toolbox, the outcomes and learning from the visit would apply to any bank throughout the world.
We also mention the EU's latest report into the failings of some banks (including DB) in respect of recent alleged money laundering scandals.
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Given its refusal to stay out of the news, we thought it was about time to turn our attention to Deutsche Bank. In an extended set of episodes we are going to examine in detail exactly what, in our opinion, went wrong and why.
Part one begins by examining the "mirror trade" affair in detail. We will bring to light previously unreported elements and also try and make sense of exactly what was the problem (HINT: It wasn't the mirror trades themselves).
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We report on our involvement in recent leaks relating to Danske Bank and the potential criminal charges that can follow a failure to report.
External reports commissioned and cancelled, suspicious activity detected but not reported and question marks over the way a whistleblower was treated. This episode has got it all!
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In this episode we start a conversation about FinTech and RegTech (along with a few digressions and diversions along the way). In an abbreviation heavy episode, we talk about face and voice validation, iris scanning and APIs, near field communication (NFC) chips and machine readable zones (MRZ) on passports and mention some of the ethical challenges that artificial intelligence and machine learning might pose.
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Following on from our last episode looking at Bitcoin and the Blockchain, this week we look at the surface web, deep web and the dark web, explain what these different terms mean and then delve into the TOR network, TOR browser, .onion sites, the Silk Road and "Dread Pirate Roberts"!
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This week, with some trepidation, we embark on an overview of some of the more esoteric elements of financial crime risk management. We attempt to explain the blockchain, cryptocurrencies like Bitcoin, and cryptography generally, in layman's terms.
As neither of us are subject matter experts in any of these fields, we are somewhat laying ourselves open to rebuttal and ridicule but we felt it was worth the risk.
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In this week's episode we talk about the glitch that was discovered in Deutsche Bank's transaction monitoring system (and a couple of other Deutsche Bank related news stories) as well as Graham's recent visit to Lithuania and their pitch to be a global centre for FinTechs (along with the fallout from the Troika Laundromat and much else).
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The one you've all been waiting for! A detailed explanation of SLPs, their history, construction and how they are used to launder money - plus a further explanation of a Scottish Limited Partnership complex structure to show how they are evolving in the light of continued public exposure.
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In this special episode we review and comment on the recent Global Witness update to its reports from last year on the effectiveness of the Companies House PSC regime.
For more see:Global Witness blog and link
Oh, and we also include an amusing update to our previous report on UK Limited Liability Partnerships.
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In an extended episode, we delve into the intricacies of UK LLPs and, using real examples, explain how the rules allow them to be constructed in a such a way as to hide ultimate ownership behind a series of entirely plausible, but geographically diverse entities.
And our old friend Ali Moulaye gets a mention (or two...).
Due to the complexities of the subject, there are supporting graphics on our website.
DISCLAIMER: There is no suggestion by us, explicit or implied, that any of the people or entities discussed in this or any other episode of "The Dark Money Files" is in any way connected to laundromat or other criminal activity. They are simply used as examples of how other actors might circumvent the rules.
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We begin our analysis of how legal entities, in locations which have transparent corporate registers can still be used to mask ultimate ownership and control while still providing a veneer of respectability.
In this first part we look at Limited Companies and their Directors, Shareholders and Persons with Significant Control, to see how each of these can look plausible but still need further investigation.
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In this first episode of season 2 we discuss Ali Moulaye, the man whose signature is at the base of Companies House account filings for a multiplicity of LLPs identified as being involved in a wide variety of laundromats. And it's quite a story!
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In a sensational final look at the Danske Bank affair, we analyse the whistleblower report and definitively link it to a UK LLP (along with a few others) a small Russian Bank with Igor Putin (cousin of Vladimir) on the board, the Deutsche Bank mirror trades, Alexander Perepilichnyy, Alexander Litvinenko, Ali Moulaye and a whole lot more.
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In 2013 Danske Bank executives started to examine,rather more critically, the lucrative bond sale business in Estonia. We look at the reporting and decision making process at the start of that journey and wonder whether, in hindsight, they might have chosen to have done things differently. We also discus the risks of doing business with unregulated intermediaries (HINT: They are very high!).
The ultimate outcome of those initial investigations is really rather surprising.
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Following the release of Phase 1 of the Forensic Risk Alliance report prepared for Swedbank, we take a detailed look at that it has uncovered and where we'd like Phase 2 to go.
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We begin to look at all the different occasions, highlighted in the Bruune and Hjejle report, where the management of Danske Bank could (and arguably should) have become aware that they had a significant problem in the Estonia Branch and taken much more assertive action to do something about it.
In this episode we look at the years from 2008 to 2010.
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The second of our special episodes looking this time at the OCCRPs newly released data dubbed "The Troika Laundromat".
Rather than spend 20 minutes criticising everyone involved we thought we'd spend some time contextualising what it means and then look at how data releases like this can be put to good effect by helping the banks to improve their detection of financial crime in the future.
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In this jaw-dropping episode we look under the bonnet at the situation in Estonia just after Danske had bought Sampo.
It highlights conflicting stories between what the Estonian regulator was saying to Danske (and in fact, ordering them to do) and what the bank was saying to the Danish regulator.
It also looks in detail at the apparent discrepancies between what they had been ordered to do and what they carried on doing.
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Following an extraordinary week of developments which saw the removal of Danske from Estonia, its voluntary departure from Latvia, Lithuania and Russia, the launching of an investigation of both Danish and Estonian regulators by the European Banking Authority, the prolonging of an argument between the two regulators by the publication of hitherto private correspondence AND the addition of Swedbank to those embroiled in the laundromat, we've recorded a special episode to talk about all these developments.
And what developments they have been!
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In this episode we begin to look at the report, commissioned by Dankse Bank, which finally brought to light the full extent of what went wrong in Estonia.
Part One explains the background to the report, the terms of reference, and the definitions of what constituted "suspicious" both in terms of customers, accounts, transactions and people associated with the bank.
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In this episode we look in some detail at payments made from Danske Estonia to three specific countries - Spain, UK, and Latvia. The outcome will surprise some and intrigue all.
It's a more complex episode because that's the way that Dark Money Launderers work and introduces, for the first time, direct references to the Magnitsky affair.
It also demonstrates that, if you look carefully enough, all of these payments, entities and schemes are connected.
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In this episode we look at a specific set of transactions within Danske Estonia - those emanating from accounts which are also located there. We do so because, of all the transactions that the bank handled, these are the ones it ought to have known most about as it would have (or should have) held "Know Your Customer" information on them. As we will see, it didn't appear to have helped them spot highly suspicious connections between supposedly unconnected accounts.
If you really want to understand why this was such a noteworthy failure of financial crime controls, this is the episode you really must listen to.
We take the audience through the many different elements that constitute "suspicious activity" and then explain those elements that are observed within the bank statements from Danske.
If you’d like more information you can always visit https://grahambarrow.com/
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Episode 2 brings a detailed explanation of the acquisition by Danske Bank of, amongst other things, the branch in Estonia which was the centre of the money laundering operation. It provides details and context as to the surrounding elements, all of which help to understand why it has been such a headline grabbing debacle.
If you’d like more information you can always visit https://grahambarrow.com/
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This is the first in a series of podcasts which explain in a non-technical way how "Dark Money" (e.g. money laundering, corruption, bribery, tax evasion) enters the financial system and infects everything it touches.
It explains what Dark Money is, why it matters and takes an early look at some of the challenges facing the banks and other financial institutions.
It also gives a flavour for some of the episodes still to come.
If you’d like more detail you can always visit https://grahambarrow.com/
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