Money Laundering Bulletin

Denmark's Danske Bank says it will likely pay around DKr15.5 billion (US$2 billion) to settle with US and domestic authorities over alleged laundering of up to ?200bn (US$15.6 billion) by non-resident customers of its Estonia branch between 2007 and 2015.

The Solicitors Regulation Authority (SRA) for England & Wales completed 225 inspections and desk-based reviews in 2021/22, finding 49 firms (22%) compliant with the Money Laundering Regulations, 133 (59%) partially compliant and 43 (19%) not compliant.

Public-private partnerships (PPP) in the anti-money laundering domain are "flourishing" across the European Union (EU) but "there is no commonly agreed definition" of how these should operate, notes new European Commission guidance.

How to launder a stack of ill-gotten banknotes is a question that doesn't just stretch the imaginations of law enforcers and AML officers, it can and does prompt useful assessments by professionals in other fields, finds Keith Nuthall.

Germany's biggest lender appears to have tried the patience of its regulator to the limit.

Three law firms that failed to operate compliant policies, controls and procedures (PCPs) against money laundering and terrorist financing have been penalised by the Solicitors Regulation Authority (SRA) of England & Wales.

UK law firms face an almost zero risk of criminal enforcement if they breach anti-money laundering laws and very little prospect of meaningful fines according to a recently published report by Spotlight on Corruption and Global Integrity. The report suggests that self-policing by the legal profession of its compliance with AML laws, through nine different professional bodies, is providing uneven and inadequate enforcement. Denis O'Connor reviews the findings, which confirm that a government target of Spring 2021 to improve the consistency of supervision of lawyers has been substantially missed.

A wholly-owned branch of the Singapore-based Oversea-China Banking Corporation (OCBC) has been ordered to pay US$1.12m by the Dubai Financial Services Authority (DFSA) for a series of anti-money laundering breaches between November 2017 and June 2022.

1/11/22: At the end of October the United Kingdom tightened restrictions on lending to Russia and banned imports of liquefied natural gas from the country, effective 1 January 2023. Additional proscriptions now apply to imports of gold, including jewellery (other than personal effects in luggage en route from Russia) and to the export and sale of 'vulnerable goods', as well to associated services. Susannah Cogman and Elizabeth Head of Herbert Smith Freehills read into the amended regulations. Also included: an update, to 3/11/22, on Australian measures against Russia.

Cryptocurrency is unstable, online payments mean an audit trail, even if convoluted, but hard cash, especially as higher denomination banknotes, facilitates anonymous transfer of value at scale: what's not to like? Keith Nuthall looks at different jurisdictions' attitudes to the physical flow of illicit funds, the academic research and canvases practitioners' views.

The balance between personal privacy and the wider security agenda appears to be tipping, in the financial crime space, in favour of more pooling of intelligence, both within and between organisations. If the trend is perceptible, internationally, the pace, inevitably, is uneven. Keith Nuthall reports from Ottawa; Sara Lewis is in Brussels; Barbara Barkhausen, in Sydney; and Julian Ryall, in Tokyo.