SAR Activity Review – Some Tips for Auditing the SAR Program – In each issue of The SAR Activity Review, representatives from the financial services industry offer insights into some aspect of compliance management or fraud prevention that presents their view of how they implement the BSA within their institution. The Bank Secrecy Act (BSA) […]

AML Spotlight on international arbitration – International arbitration provides a very tempting proposition for organised criminals seeking an apparently legitimate cover for moving large amounts of criminally obtained money from one jurisdiction to another. The laundering methodology behind the use of arbitration, as with litigation, is that criminally sourced funds are placed in what appears […]

2012 Olympics: where is the money laundering threat for solicitors? – The London Olympics this summer will provide a fantastic opportunity to showcase the best of the UK in terms of sport, culture, business and national heritage. However in order for events to run smoothly, firms across the UK are busy preparing for disruption to […]

Help! I’m a new MLRO – the verification of source of funds – Each firm will have its own distinct culture and way it does business. How a firm engages with its anti-money laundering obligations will be determined, in part, by its culture and the approach taken by its senior management and MLRO. Over time […]

Solicitor’s conviction for money laundering overturned – A solicitor was found not to have made false declarations on the certificate of title despite failing to disclose his financial interest in the transaction, resulting in his convictions for money laundering and mortgage fraud being overturned. Mr Cornelius undertook conveyancing for a firm in Swansea and also […]

When is an arrangement not an arrangement? – Police are entitled to rely on intelligence information and information provided by solicitors in suspicious activity reports when they are assessing whether it is appropriate to apply for a warrant to search the solicitor’s office or to arrest the solicitor on suspicion of money laundering offences. So […]

The FSA consults on changes to the approved persons’ regime to improve corporate governance. On 28 January 2010, the FSA published a consultation paper entitled: “Effective corporate governance (Significant influence controlled functions and the Walker review)” (CP10/3). The FSA’s proposals reflect its ongoing work on governance in regulated firms and address a number of the […]

Islamic finance and ensuring the agreement is upheld in the event of a dispute – what should investors or other parties to an agreement with an Islamic finance institution do to ensure that the agreement is upheld in the event of a dispute? They should: ensure they obtain and fully review the constitutional documents of […]