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Comsure operates in:the UK, Jersey, Guernsey


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Isabella discusses the latest financial crime news with Samantha Sheen and Misha Glenny.

They cover the latest developments with: the impounded Iranian oil tanker the Adrian Darya-1, HMRC’s largest-ever money laundering fine and the trailer of the Laundromat film. In the deep dive, Matthew Redhead tells us about his forthcoming paper on the effectiveness of the AML regime and what can be done to make it more effective. […]

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JERSEY amends AML laws and JFSC rules-codes (the handbook)

Following the Money Laundering (Amendment No.10) (Jersey) Order 2019 coming into effect on 12 June 2019, https://www.jerseylaw.je/laws/enacted/Pages/RO-041-2019.aspx the following amendments should be noted:- Amendment of Money Laundering (Jersey) Order 2008 Article 1 (interpretation) amended Article 3 (meaning of “customer due diligence measures”) amended Article 10A (financial services business carried on outside Jersey) amended Article 11 […]

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Guidance on managing the risk of Customer Tax Evasion

The Wolfsberg Group is pleased to publish its Guidance on Customer Tax Evasion, which is designed to provide Financial Institutions (FIs) with an industry perspective on how to develop, implement and maintain an effective anti-tax evasion compliance programme. The overall objective of the Guidance is to promote a culture of ethical business practices and compliance […]

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FCA ENFORCEMENT CASE STUDIES – Lessons learnt?

LEARN FROM OTHER PEOPLES MISTAKES – Enforcement action was taken by the FCA about 1] culture and governance; 2] operational and technological resilience; 3] financial crime and money laundering, and 4] the treatment of customers. Cases matched against the above are discussed below:- 1.Firm’s culture and governancei it is expected that individual accountability, culture and […]

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Spotlight on Money Laundering in 2019

Summary What Next? Driving dirty money out of the UK financial system has become an increasing priority for the FCA, reflecting the higher profile which money laundering now has in the UK. This profile stems from a variety of sources, including the political focus on tackling the proceeds of crime, media investigations into tax evasion […]

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SRA AML audits: be prepared

The Solicitors Regulation Authority (“SRA”) confirmed in March that it will be writing to a “large number” of firms (400) asking to see evidence of compliance with the Money Laundering Regulations 2017 (“MLR 2017”). A failure to respond to the SRA request can have regulatory and criminal consequences. This action is taken under powers set out in the SRA […]

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HONG KONG Latest SFC inspection findings on AML/CTF systems and controls

Hot on the heels of the of the HKMA’s actions against Shanghai’s Commercial Bank in mid-August as well as Hong Kong’s ML/TF Risk Assessment in April The Securities and Futures Commission (“SFC”) issued a robust circular on 31 August 2018 about the adequacy of LICENSED CORPORATIONS’ (“LCS”) Anti-Money Laundering, and Counter Financing of Terrorism (“AML/CFT”) […]

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Revealed: number of suspicious financial transactions in Hong Kong more than quadruples in six years

Hong Kong’s financial system is groaning under a deluge of tens of thousands of suspicious financial transaction reports, the number of which has more than quadrupled over the past six years. In 2017 the Joint Financial Intelligence Unit – which acts as a clearing house for reports of suspicious activity filed by banks and other […]

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