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Comsure operates in:the UK, Jersey, Guernsey


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Four Lists of Red Flag Indicators for Terrorist Financing

Four Lists of Red Flag Indicators for Terrorist Financing Financial and Behavioral Indicators Published by The Egmont Group of Financial Intelligence Units Indicators linked to the financial transactions: The use of funds by the non-profit organization is not consistent with the purpose for which it was established. The transaction is not economically justified considering the […]

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Fourth Money Laundering Directive – increased risk management requirements

On 25 June 2015 the fourth Money Laundering Directive (“Directive”) entered into force. http://bit.ly/1gPQ0pK The Directive applies to a broad range of businesses from banks and financial institutions to auditors, tax advisors and legal professionals. The European Union continues to tighten its grip on money laundering and, to this end, the Directive provides a number […]

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WHEN BASIC AML TRAINING JUST ISN’T ENOUGH

Deutsche Bank is reportedly leading an internal investigation into an alleged USD6bn laundry, using ‘relatively simple transactions’ to clean cash. Simple transactions used to launder money should be easy to identify – if the software does not pick it up, then the employees handling the transactions should be able to spot a suspicion. Basic anti-money […]

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Jersey AML landscape after 2014

The 2014 amendments to the AML offences, together with the proposed revisions to the handbook, are indicative of the JFSC’s continued focus and commitment to strengthening the AML framework and ensuring that it is in line with the MoneyVal recommendations.  The sea change being ushered in is further evidence of the need to ensure that […]

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SRA v Andrew Donald Varley

Summary: The Respondent failed to identify the indicators of property/mortgage fraud/money laundering further to the documented link between the buyer introducer and mortgage broker, and the payment of money on the introducer’s instructions to unknown and unidentified third parties. The SRA argued that the Respondent showed a reckless disregard for his money laundering obligations in […]

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FCA fines for failings in anti-money laundering controls – lessons for all firms

Recently the FCA have been relatively silent on any AML failings in firms – this said however the FCA (and the FSA before them) has over the long term shown an increased interest in tackling financial crime. Thematic reviews A number of thematic reviews have been conducted within the banking, insurance and asset management sectors […]

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Iraj Parvizi v Barclays Bank – SARS – Anti-Money Laundering Case Update

SARS tested in court – Iraj Parvizi v Barclays Bank The recent case of Iraj Parvizi v Barclays Bank [2014] EWHC B2 (QB) was heard in the High Court on 21 May 2014. Key themes considered in the case were the Proceeds of Crime Act 2002 (“the Act”) and the meaning of suspicion giving rise […]

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HMT ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCE SUPERVISION REPORT

HM Treasury has published its anti-money laundering and counter terrorist finance (AML/CFT) supervision report for 2013-14. The report provides a number of case studies of good practice by individual supervisors as they seek to meet the challenges set by the new Financial Action Task Force (FATF) methodology of assessing countries’ AML/CFT regimes. http://bit.ly/1DYJsZH

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