Money Laundering Bulletin
Mirror trading – clear reflection
Damon Batten (+44 (0)20 7620 8440, dbatten@bovill.com) is a managing consultant with Bovill.

A year has passed since the UK Financial Conduct Authority (FCA) levied its largest fine, against Deutsche Bank over anti-money
laundering (AML) failings relating to a series of ‘mirror trades’ originating in Russia. [1] Despite continuing regulatory
focus, faced with complexity in monitoring trading across legal entities and jurisdictions, firms are struggling to demonstrate
how they can detect and prevent similar breaches.
Damon Batten of Bovill maps a control framework.