On the 24th of March 2015 the FCA released their business plan for the year. A notable aspect of the plan was financial crime replacing house price growth as a top risk consideration. Additionally, the FCA placed a special focus…
4 things we can learn from PayPal’s sanction violations
On the 25th of March 2015 PayPal agreed a $7.7m (£5.1m) settlement with U.S officials due to a breach of OFAC sanction regulation. For several years, up until April 2013, PayPal had been allowing users of their service to channel…
Why does ultimate beneficial ownership matter?
The joint-stock company is a social innovation that made possible global capitalism today. The array of corporate vehicles that it has spawned – limited liability corporations, trusts, limited companies and other legal structures – make possible the investment of capital and the…
Cryptocurrency, Financial Crime and Regulation
The recent HM Treasury publication, “Digital Currencies: response to the call for information”, reported that 80% of respondents believe digital currency requires a form of regulation. In addition, due to the anonymous nature of digital currency, participants acknowledged that money…
Do multinationals have robust enough compliance procedures?
Given the plethora of recent compliance mishaps by multinational banks, highlighted most recently by HSBC’s tax evasion scandal, the question arises as to whether multinational companies have robust enough compliance procedures. HSBC’s admission that “we review all Politically Exposed Persons…
AMLD4 and Domestic PEPS
AMLD4, the 4th amendment to the Anti-Money Laundering Act will update the European Union’s existing Anti-Money Laundering and Counter-Terrorist Financing laws by implementing recommendations made by the Financial Action Task Force, the international global standard setting body of AML and…
Why is HSBC unable to resolve its money-laundering issues?
The wave of fines levied against financial institutions has not stopped since the financial crisis of 2008 precipitating financially and reputationally expensive recapitalisations of British and international banks. Despite this, even by 2015, the waves of fines is ongoing, as…
Fincen: Sanity Required Over Wholesale Termination of MSB Accounts
Fincen yesterday issued a statement regarding the extent to which banks should terminate the accounts of MSB’s. The statement declared: MSBs play an important role in a transparent financial system, particularly because they often provide financial services to people less…
Is searching OFAC enough?
At the time of writing, the OFAC SDN list contains 5,466 entities. This list proscribes the entities that on a statutory basis, companies and individuals can not deal with. However, it is apparent that regulators and counter-parties alike do not consider this enough….
“Cutting Off Customers Can Backfire”
According to the Wall Street Journal, HSBC recently stated that it has “closed accounts in certain segments,”. According to the WSJ, Mr. Werner, speaking at a New York State Society of Certified Public Accountants event said that “We’ve done it because we have shareholders and…
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