The recent fallout from the “Panama Papers” data leaks have not only thrown the use of offshore tax havens and fiscal transparency back into the spotlight, but also highlighted the threat of data security breaches and associated compliance risks to corporates, including law and accountancy firms. The debate needs to move on from “offshore bad” […]

The JFSC response to the Panama Papers should prompt you all to review the recent Trust Company Business Examination Feedback reports In light of the recent news about the Panama Papers and the JFSC responses (JEP 7/4/2016) about Jersey’s safeguards, I think it is worthwhile revisiting the Jersey Financial Services Commission (JFSC) summary findings from […]

In light of the Panama Papers scandal (https://panamapapers.icij.org/ ) it may time to ask ourselves what does ‘beneficial ownership’ mean for AML purposes? There is no universal and finite definition of ‘beneficial owner’. Various bodies, governments and institutions differ in their interpretation, and it also depends on the legal person’s form. The Financial Action Task Force […]

Finally an international organisation recognises that Money laundering is more than a linear process of Placement, Layering & Integration – as shown below Transparency international provided the following definition The process of concealing the origin, ownership or destination of illegally or dishonestly obtained money [AKA the proceeds of crime (POC)- ED] by hiding it within […]

When will financial services firms understand that data & information security is paramount….just consider the problem Mossack Fonseca now have. Over a year ago, an anonymous source contacted the Süddeutsche Zeitung (SZ) and submitted encrypted internal documents from Mossack Fonseca (http://www.mossfon.com/) who markets itself as a leading global company which provides comprehensive legal and trust […]

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Does the following JEP news headline and article suggest that crime does pay….? Joking aside, maybe all the hard work that is put in by financial services to detect the Proceeds of Crime and Report (SAR) should be rewarded, by having some of their JFSC fees (just gone up again!!) underwritten with the seized assets? 

At the time of writing (20/01/16) Guernsey are digesting their long awaited MONEYVAL report on Money Laundering [ML] and Financing of Terrorism [FT]. Generally, the report is very good and hopefully Jersey’s report will be as good, if not better! This said, there is a “fly in the ointment” and this is in relation to […]