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re you can place your bid you can put your maximum and the system will bid up to that for you if needed happy bidding to you all share this email a link to a friend opens in new window email print opens in new window print share on facebook opens in new window facebook share on linkedin opens in new window linkedin share on x opens in new window x like loading posted in uncategorized tagged aml auction cufflinks mlro money laundering reporting officer mug training workshop 4 comments please release me posted on november 17 2021 by susan grossey author the principle of mitigation is an important one in the justice system once someone has pleaded guilty to an offence or been found guilty of it after a trial the attention of the court turns to sentencing and this is when mitigation comes in and will certainly be more generous in the former situation than in the latter the defence uses all of its skill to urge the judge or magistrates to move downwards from the starting point sentence which is at least in the uk specified in the publicly available sentencing guidelines and the prosecution usually rebuts these blandishments seeking a more robust sentence what amuses me is how criminals who have been shown to be utterly professional and ruthless throughout the court process are keen to emphasise their vulnerability when it comes to sentencing i m not saying that mercy should not be shown i m simply observing that it s fun to watch the screeching u turns two recent money laundering cases comes to mind in the first bruce bagley a former university of miami professor whose area of research was irony alert latin american drug trafficking and organised crime pleaded guilty in june 2020 to receiving us 2 5 million in deposits from bank accounts in switzerland and the uae that was embezzled from venezuela and then retaining a commission he has been held on remand since his arrest in november 2019 and as his sentencing hearing approaches his attorneys have filed a request that he be sentenced to time already served and released immediately citing his age 75 and ill health and saying that it is altogether reasonable to predict that he will never be a repeat offender personally i would have gone for the more convincing he has assured us that but then i am a picky pants prosecutors have said that bagley has shown no remorse and are asking for a sentence in the range 46 57 months that s 3 8 to 4 75 years you re welcome and this very morning he has been jailed for six months and in the second we have the case of graham the wig whelan in ireland no i don t whether he wears a wig or is good at disguise or listens in on private conversations another mystery now mr whelan is not a nice man in march 2000 when he was only 17 he was caught with 1 5 million worth of cocaine and ecstasy in the holiday inn in dublin and jailed for six years this drugs bust was the start of a notorious feud between crime families whelan was part of the kinehan family in which sixteen people died and whelan matured as a criminal he racked up 33 convictions including violent disorder criminal damage assault and grievous bodily harm in january 2019 whelan was arrested at the intercontinental hotel in dublin in possession of 1 275 cash when he was asked where it was from he told officers he had got from up his swiss roll and that they could keep it ewww and wearing an audemars piguet royal oak watch worth 28 000 he pleaded guilty to money laundering including paying his hotel bill of 2 140 with the proceeds of crime on 15 november 2021 he was sentenced to eighteen months in prison and then asked the judge to delay sending him to prison until january so that he could spend christmas with his kids the judge declined this interesting offer i am assuming on the basis of that other sound legal principle you should have thought of that earlier share this email a link to a friend opens in new window email print opens in new window print share on facebook opens in new window facebook share on linkedin opens in new window linkedin share on x opens in new window x like loading posted in uncategorized tagged aml cash financial crime legislation money laundering organised crime proceeds of crime sentence leave a comment dull as dishwater posted on november 10 2021 by susan grossey author one of the most common requests i have from people commissioning my training is for case studies stories about money launderers and i am more than happy to oblige as researching these creatures is one of the guilty pleasures of my life take yesterday for instance when this headline flashed across my screen mexico s anti money laundering chief resigns amid scandal well who could resist turns out it might not be anything to do with money laundering the head of mexico s fiu got married and on the private plane he hired to take influential guests to his wedding in guatemala there was also a bag containing us 35 000 in cash which was apparently correctly declared and intended to be spent on medical treatment in the us but i have questions how can the head of an fiu afford private planes why does he have influential guests and do doctors in the us really accept bags of cash however i think it is important to get the message across to staff who are after all your front line defence that money laundering is not always indeed not usually as fun and glamorous as this most money laundering is dull pedestrian and unambitious as an example i often tell the story of ian woodall who worked for westminster council as an interim chief investment officer between january 2009 and december 2012 he stole 924 841 from the council by tricking colleagues who trusted his advice into signing off on payments from their billion pound pension fund by telling them that he was making investments and in a way he was he was investing in his own house and car and morally interesting this he paid off his tax bill at hmrc the laundering came about because woodall transferred the money from his uk bank account to accounts he had opened for this purpose in switzerland the theft was uncovered in september 2013 when an audit into the council discovered almost 1 million had been unlawfully removed and in january 2019 woodall was jailed for seven years no private jets no glamorous birthday parties stuffed with influencers no fleet of diamond encrusted sports cars but all the more missable for it if we feed staff a constant diet of high level high octane high glam stories about top level criminals and corrupt peps we risk them getting the idea that all money laundering is like that in reality it s mostly quiet modest and sneaky it happens every day in most financial institutions and we need to remind them of that so for every obiang in your training make sure you include a woodall as well share this email a link to a friend opens in new window email print opens in new window print share on facebook opens in new window facebook share on linkedin opens in new window linkedin share on x opens in new window x like loading posted in uncategorized tagged aml cash communication financial crime mlro money laundering proceeds of crime training white collar crime 5 comments underfunded under supervised and over here posted on november 3 2021 by susan grossey author i know i know who thought i would spend my last few months as an aml er shaking my fist impotently at the madness that is freeports but here we are i ve written before here and here about why they re such a bad idea from the point of view of money laundering and how they will further damage our international reputation such as it is for financial uprightness but recently i ve spotted a few stories that address something more basic more concrete more old fashioned if you will the physical security of freeports and customs warehouses and bonded warehouses quick and shameless plug if i may my fourth sam plank novel portraits of pretence includes a murder in a thames side bonded warehouse in 1827 exciting stuff you will remember i am sure hmg s reassuring confirmation that the government does not want the introduction of uk freeports to lead to an increase in illicit activity and that as part of the authorisation process checks will be conducted on freeport operators and businesses operating to ensure they do not present and undue risk and that freeport operators have adequate policies in place to ensure control over the movement of goods all very well in theory but as this article from the guardian way back in november 2002 shows we were already hampered by the slow motion disaster inside an underfunded and under supervised customs the culture was already more business friendly as red tape was cut and the emphasis shifted to facilitating trade while customs officers were pulled back from the ports and warehouses and staff cut i appreciate that this is a report from nearly twenty years ago but can we believe that hmrc has bucked the trend of every other government agency and in the past two decades has received more funding and better supervision and with our standard ports already under supervised how will we cope with the new freeports as well with an underfunded and under supervised and presumably demoralised workforce can we really be sure that people working in the freeports or with access to them will be screened and monitored robustly enough in august 2020 a man pleaded guilty to stealing nearly 300 iphones from a customs warehouse in new jersey in the us he worked for a maintenance contractor to the treasury executive office for asset forfeiture which gave him access to the warehouse for a three week period and each day at work he stuffed a few phones down his trousers and boots actually if he worked there for fifteen days that s twenty phones a day down his britches i assume they were oxford bags and just to pull us back to money laundering again on 8 october 2021 three men were jailed in london for laundering 25 million from the sale of alcohol where duty was not paid through their cash and carry warehouses i know it s a different sort of warehouse but the men presumably identified by banks and solicitors as running a cash and carry operation and subjected to relevant cdd checks moved millions through a network of shell companies the money laundering was exposed when investigators discovered that the shell companies claiming to be legitimate alcohol sales businesses had no storage facilities for the bottles and were fronted by people with no experience of the trade with such basic schemes still working so well i fear for the future and take little to no comfort from hmg s desire that the new freeports should not lead to an increase in crime and requirement for them to have sadly unambitious adequate procedures share this email a link to a friend opens in new window email print opens in new window print share on facebook opens in new window facebook share on linkedin opens in new window linkedin share on x opens in new window x like loading posted in uncategorized tagged aml anti money laundering due diligence financial crime freeport hmrc money laundering organised crime proceeds of crime smuggling tax evasion leave a comment i long for a verwijzingsportaal bankgegevens posted on october 27 2021 by susan grossey author apologies for the unexpectedly long silence i was felled by covid thankfully i am on the mend and once more have enough energy for outrage and indignation i had a dutch boyfriend for several years during which time i developed a liking for salty liquorice and an extremely limited dutch vocabulary one phrase he did not teach me was verwijzingsportaal bankgegevens but isn t it marvellous it s the dutch bank data retrieval portal and since 1 january 2020 all dutch banks have been obliged to connect to it well not all of them according to article 32 a of the fifth money laundering directive it s required if you offer bank accounts with ibans or safe deposit boxes and the purpose is to allow access to this information to those investigating financial crime such as police public prosecutors fius and tax authorities i of course think it s an excellent idea but then you know how pollyanna ish i am about transparency and information sharing once brexit raised its unbelievably ugly head i knew that the uk s commitment to mld5 was shaky yes we were still in the eu when the implementation deadline passed but what could they do about it if we didn t comply yah boo sucks to them we said there was plenty of lip service paid to the idea of maintaining standards but we all know which side our plain boring sliced white bread is buttered and according to an article on the law society website i cannot find any announcement on the home office website please let me know if you can and i ll share the link the uk s plans to build such a portal have been quietly shelved over the summer despite the fact that such a portal would undoubtedly help with aml cft endeavours apparently the home office has done a cost benefit analysis and decided that the possible efficiency benefits of a portal were uncertain a register might not deliver the level of change needed and building a portal would be costly to the public and private sectors oddly the law society comments that we welcome the cancellation as it avoids imposing further regulatory burdens on firms and adding to compliance costs as the portal would be fed by banks not law firms i assume they mean that it would be a hassle for law firms to have to respond to queries thrown up by interrogation of the portal and so it begins the dismantling of the aml cft safeguards that we have spent decades slowly painfully gradually building i can hardly bear to watch i may return to my sick bed and afternoon re runs of hart to hart share this email a link to a friend opens in new window email print opens in new window print share on facebook opens in new window facebook share on linkedin opens in new window linkedin share on x opens in new window x like loading posted in uncategorized tagged aml anti money laundering bank account bank account portal cdd fifth money laundering directive fiu investigation mld5 police tax authorities leave a comment older posts welcome howdy and welcome to my blog if you d like to get instant updates whenever i ve been inspired or irritated enough to write something please do subscribe the day job when i m not writing this blog i m doing aml training writing research and advice obsessed hell yeah to find out more have a look at my website be the first to hear enter your email address to follow this blog and receive notifications of new posts by email email address sign me up search for the solo squid how to run a happy one person business heir apparent the sixth sam plank novel free official guide to the sam plank mysteries sample chapters and glossary new e boxset of first three sam plank e books click image to buy faith hope and trickery the fifth sam plank novel new piggy in the sty this one is for uk 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