INTRODUCTION The acclamation and social status that are linked to a winning team combined with the investment in clubs with little apparent expectation of a financial return have made the industry attractive to some criminals. The European Commission (Commission)  recognises that sport can be attractive to criminals in order to launder funds due to the […]

On 18 June 2019 the Guernsey Financial Services Commission (“the Commission”) announced it has fined Louvre Trust (Guernsey) Limited, Derek Paul Baudains, Jonathan Ross Bachelet, Haidee Louise Stephens, Julian Dai Lane, Charles Peter Gervais Tracy as follows £70,000 on Louvre Trust (Guernsey Limited) (the “Licensee” or the “Firm”) under section 11D of the Financial Services […]

On 8 May 2019, the Central Bank of Ireland found Campbell O’Connor & Company, a private client stockbroker, guilty of five breaches of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010) between July 2010 and November 2016. These breaches comprised of failings in the firm’s anti-money laundering and combating the financing […]

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 […]

Example of good and poor practices, which provide guidance that is helpful. Also, this is to a reminder of supervisory expectations. The FCA has published TR18/3 presenting a outcome from its thematic review of the anti-money laundering (AML) and counter-terrorist financing (CTF) system and controls in thirteen Electronic Money Institutions (EMIs). Also the overview, just […]

In Krolls 2015 ABC Report, Kroll asked respondents to identify what they considered to be the type of corrupt behavior the chief compliance officer must guard against. The primary answers are bribery (93%), money laundering (61%), bid-rigging (60%), and price fixing (56%). Trailing further behind “the big four” corruption risks are conflict minerals (27%) and […]

The Jersey Financial Services Commission (JFSC) [Issued: March 2010] published a report on findings into its Anti-Money Laundering examination of Trust Company Business in Jersey. TRUST COMPANY BUSINESS ON-SITE EXAMINATION PROGRAMME 2009 – SUMMARY FINDINGS http://www.jerseyfsc.org/pdf/TCB_2009_Examination_feedback_March_2010.pdf In the report the JFSC reported on some the following matters 1.Business Risk Assessment and Strategy 2.Customer Profiling and […]

Most companies understand the strategic benefits of an effective system for internal control. In 2013 alone, Thomson Reuters tracked over 26,000 regulatory changes, and with emerging risks on the horizon, many organizations are seeking new perspectives on how to put principles into practice in their complex operations. The COSO Internal Control – Integrated Framework (2013) […]