Part 233 : Economy & Policy Part 2 : UK's Role in Global Money Laundering Challenges 2. Law Enforcement and Judicial Cooperation: Theoretically Strong, Practically Weak These bodies are designed for direct action but face immense practical and political hurdles. a) International Criminal Police Organization (INTERPOL) *Role: Facilitates cross-border police cooperation, notably through Red Notices (requests to locate and provisionally arrest a person). *Effectiveness: Limited and often misused. Kleptocrats and their allies have been known to abuse INTERPOL systems to harass dissidents and opponents. While useful for sharing information, it does not directly tackle the financial structures of money laundering. b) Europol (for the EU) *Role: The EU's law enforcement agency, facilitating information sharing and coordination. *Effectiveness: Diminished post-Brexit. The UK lost direct, real-time access to Europol's databases and is now a "third country," making cooperation slower and more bureaucratic. This has hampered the fight against cross-border financial crime, which is inherently international. c) Mutual Legal Assistance Treaties (MLATs) *Role: Bilateral agreements for exchanging evidence and assisting in prosecutions. *Effectiveness: Notoriously slow, complex, and politically fraught. Requests can take years. Kleptocrats often use the UK's own legal system to challenge MLAT requests, tying them up in costly courts. If the country requesting assistance is itself corrupt, trust in the process breaks down. 3. Standard-Setting and "Soft Power" Bodies: Indirect but Important a) Organisation for Economic Co-operation and Development (OECD) *Role: Sets international standards, including the Anti-Bribery Convention. *Effectiveness: Moderate. Its Working Group on Bribery conducts peer reviews that have criticised the UK's inconsistent record on prosecuting foreign bribery (e.g., the initial failure to pursue BAE Systems allegations aggressively). This creates diplomatic pressure for stronger action. b) The Egmont Group of Financial Intelligence Units (FIUs) *Role: A network of national FIUs (in the UK, this is the NCA's National Economic Crime Centre) that share financial intelligence. *Effectiveness: Technically effective but overwhelmed. Information sharing is crucial for tracing dirty money. However, UK agencies are chronically under-resourced and face an avalanche of Suspicious Activity Reports (SARs), most of which they cannot process effectively. A Chinese famille-verte vase, Qing Dynasty, 19th century the ovoid body painted with a scholar seated at a table attended by a small boy observing two maidens and their small boy attendants, with a rocky outcrop issuing plantation tree, the neck similarly decorated, the shoulders with Buddhist emblems interspersed with flowerheads,
UK's Role in Global Money Laundering: Challenges and Efforts
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Part 232 : Economy & Policy Part 1 : UK's Role in Global Money Laundering Challenges The effectiveness of international anti-corruption agencies in stopping Britain's role as a "global laundromat" is a story of both significant limitations and emerging, cautious progress. It's crucial to understand that there is no single, powerful "international anti-corruption agency" with direct enforcement power in the UK. Instead, effectiveness depends on a fragmented ecosystem of organizations with different tools: naming-and-shaming, setting standards, facilitating cooperation, and (in a few cases) limited enforcement. 1. The "Naming and Shaming" Bodies: Moderate to High Influence These agencies have no direct power to arrest or prosecute but wield significant influence by creating reputational and political pressure. a) Financial Action Task Force (FATF) *Role: The global money-laundering and terrorist-financing watchdog. It sets international standards (the Recommendations) and conducts peer reviews of countries. *Effectiveness: Potentially high, but slow. The UK prides itself on having a technically robust legal framework. However, FATF's 2018 Mutual Evaluation Report of the UK was critically important. It praised the UK's laws but blasted its ineffective enforcement, particularly regarding "unexplained wealth orders" (UWOs) and prosecutions of professional enablers (lawyers, accountants). *Impact: This international shaming was a key driver behind the UK government's subsequent efforts to reform and strengthen its agencies, such as the National Crime Agency (NCA). The threat of being "grey listed" (a mark of shame for a major financial centre) is a powerful motivator for the UK government to at least be seen to be taking action. b) Transparency International (TI) Role: A global civil society organization, not a government agency. Its power is in research, advocacy, and public campaigning. *Effectiveness: Highly influential in setting the agenda. TI UK's seminal reports, like "Money Laundering on a Global Scale: How the UK is at the heart of the dirty money epidemic", first popularised the term "London laundromat." Their work meticulously documents the problem of opaque property ownership, the role of enablers, and weak enforcement. *Impact: They keep the issue in the news, provide MPs and journalists with ammunition, and push specific legislative proposals (e.g., the register of overseas entities) onto the political agenda. Porcelain rouleau famille verte vase, China, Qing dynasty, of the Kangxi period (1662-1722).
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The Financial Action Task Force (FATF) together with the Egmont Group, INTERPOL, and UNODC have launched a new handbook on international cooperation aimed at improving detection, investigation, and prosecution of money laundering. The core message is that money laundering is inherently transnational, and criminals exploit gaps between legal systems. To combat it effectively, countries must cooperate more efficiently across borders. Historically, investigations and prosecutions of money laundering have been weak globally; one cause is the slowness and complexity of formal legal cooperation. The handbook seeks to complement formal procedures with more nimble “informal” mechanisms. What the Handbook Offers Practical tools and guidance for financial intelligence units (FIUs), law enforcement agencies (LEAs), and prosecutors to help them cooperate more effectively across jurisdictions. Emphasis on informal cooperation mechanisms — e.g. secure communication channels, rapid-response cooperation, joint intelligence/analysis — to supplement formal mutual legal assistance (MLA) and conventions, which can be slow or encumbered by procedural constraints. The handbook is accompanied by three subsidiary “practical guides / brochures tailored to FIUs, law enforcement, and prosecutors. Illustrative Cases & Impact To demonstrate how international cooperation can yield real results, the announcement includes several case examples: FIUs in Italy, Spain and the Netherlands combined intelligence to uncover a cross-border laundering scheme of EUR 95 million. Operation AVARUS-X in Australia (with support from U.S. Homeland Security) targeted a network using money-service businesses to move billions of AUD illicitly. U.S. and Indian authorities coordinated to seize USD 150 million in cryptocurrency assets tied to drug trafficking. An INTERPOL-supported operation involving multiple countries led to convictions in Singapore for rhino horn trafficking, using evidence sourced from South Africa. These cases show how leveraging cooperation—across FIUs, law enforcement, and judicial authorities—can deliver tangible outcomes (asset seizures, convictions). Challenges & Calls to Action Because formal legal cooperation (e.g. mutual legal assistance) can be slow, bureaucratic, and limited by divergent legal frameworks, the handbook stresses the need to enhance informal cooperation. It calls on states to adopt rapid response mechanisms, maintain secure channels for information sharing, and develop joint analysis capabilities. The launch comes in the lead-up to the 2026 UN Crime Congress (to be held in UAE), which will be a forum for states to exchange practices and renew commitments on financial crime investigations.
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The Financial Action Task Force (FATF), Egmont Group, INTERPOL, and the UN Office on Drugs and Crime (UNODC) launched the International Co-operation on Money Laundering Detection, Investigation, and Prosecution Handbook to address the critical need for stronger global collaboration against financial crime. The initiative is based on the finding that investigating and prosecuting money laundering remains one of the weakest areas worldwide, largely due to criminals exploiting gaps between national legal systems as their activities cross borders. Key Features and Call to Action The joint effort calls for stronger collaboration among analysts, investigators, and prosecutors, emphasizing the need for faster intelligence and action to keep pace with globalized financial systems and rapid technological advancements. 1. The Handbook's Focus: Speeding Up Investigations The handbook provides practical tools to help countries accelerate investigations and bring more criminals to justice. Its central theme is the promotion of informal cooperation, such as: * Secure communication channels * Rapid response mechanisms * Joint analysis This informal approach offers faster, more flexible, and targeted investigations that complement slower, procedurally complex formal legal processes. 2. Tailored Practical Guides To ensure effective implementation, the organizations also developed three specific practical guides tailored for different practitioners: * Financial Intelligence Units (FIUs) * Law Enforcement Agencies (LEAs) * Prosecutors 3. Demonstrating Impact The publication highlights real-world examples of successful international cooperation, including: * Uncovering a €95 million cross-border laundering scheme through joint analysis by FIUs in Italy, Spain, and the Netherlands. * The seizure of $150 million in cryptocurrency assets linked to drug trafficking through real-time coordination between U.S. and Indian authorities. FATF, Egmont Group, INTERPOL and UNODC call for stronger co-operation between countries as they launch handbook to fight money laundering https://lnkd.in/gRf_8h4A
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ALCB “ALCB” is the French abbreviation typically meaning “Anti-Laundering of Capital and the Financing of Terrorism”, but in context here it seems to refer to cooperation between Financial Intelligence Units (FIUs) as a “best practice” in international cooperation. what seems important - International cooperation is central: The example with France and Luxembourg shows how cross-border collaboration can unearth complex fraud schemes that single countries might struggle to trace alone. - Legal & technical harmonization matters: Without common formats, consistent legal powers, and good access to necessary registers (ownership, company, bank accounts), joint analyses and investigations get harder, slower, and less effective. - Secure communication channels are critical: Using FIU.net, ESW, etc., seems indispensable for confidentiality, trust, and legal safety. - Resource constraints are real: Varying capacities across FIUs are a structural challenge; even if the will is there, the manpower, technology, or legal tools may not be evenly distributed. - Regulatory institutions (like AMLA) have potential to strengthen common frameworks, but real-impact depends on implementation, not just regulation on paper. https://lnkd.in/dEscNCcG
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We are proud to share that Guest Work Agency contributed to the Anti-Money Laundering Regulations and the Art Market Comparative Study, an international initiative led by the Center for Art Law. The study provides a comparative analysis of anti-money laundering obligations across jurisdictions and their impact on art market professionals. GWA’s contribution addresses the Australian legal framework, situating it within the broader global context. You can read more about our involvement and the findings here: https://lnkd.in/g7nh3CSR
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Handbook to fight Money Laundering The Financial Action Task Force (FATF), Egmont Group of Financial Intelligence Units, INTERPOL and the @United Nations Office on Drugs and Crime (UNODC), are calling for stronger #global #collaboration among analysts, investigators, prosecutors and others as they launch a practical Handbook on International Cooperation against #MoneyLaundering, providing essential tools to help countries speed up investigations and bring more criminals to justice. #Moneylaundering almost always crosses borders, and criminals exploit gaps between national legal systems to hide their activities and avoid punishment. Yet, Financial Action Task Force (FATF) evaluations consistently show that investigating, prosecuting and sanctioning money laundering remains one of the weakest areas worldwide. Without more effective co-operation, countries cannot stop financial crime in its tracks. Financial Action Task Force (FATF) President, Elisa de Anda Madrazo said: “An international threat requires an international response. A victim can often be on the other side of the world to the criminals that are destroying their lives or livelihoods, so we need to see countries working more effectively together and multiplying our defences to keep people safe, bring more criminals to justice and recover ill-gotten gains.” Speeding up investigations The handbook responds to the #globalisation of financial systems and rapid technological advancements, which demand faster intelligence and action to keep pace with criminals. #Complianceofficers #Complianceprofessionals Super Pearls Professionals
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How to find #clarity and #coherence if it’s not only internal policy could be confusing, but also Governments MLR proposal : “(This step risks confusion, inconsistency, and weakened credibility ahead of the UK’s FATF evaluation”)
The Draft MLRs propose narrowing “high-risk third countries” to just FATF’s Call for Action list. That's only Iran, North Korea and Myanmar. This excludes sanctioned jurisdictions like Russia, despite supervisors, insurers, and sanctions law already requiring enhanced checks. This step risks confusion, inconsistency, and weakened credibility ahead of the UK’s FATF evaluation in 2027. The consultation closes on 30 September. It’s important that voices from across the profession stress the need for a consolidated UK list that reflects reality. If you share these concerns, now is the time to respond. The more voices HM Treasury hears, the greater the chance of change. https://lnkd.in/e5dDQvPg
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“As regulations develop, and as sanctions regimes tighten, the requirement for ongoing monitoring becomes even more important. Put simply, Art Market Participants need to ensure that they have a process in place that allows them to ‘rerun’ checks on their customers more than once, and routinely as their customers continue to conduct business with them.” https://lnkd.in/gp6_sCgn
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📘 𝙀-𝙗𝙤𝙤𝙠: 𝙉𝙚𝙬 𝙀𝙐 𝘼𝙣𝙩𝙞-𝙈𝙤𝙣𝙚𝙮 𝙇𝙖𝙪𝙣𝙙𝙚𝙧𝙞𝙣𝙜 𝙇𝙚𝙜𝙞𝙨𝙡𝙖𝙩𝙞𝙤𝙣 𝟮𝟬𝟮𝟱 2024 marked a turning point in European anti-money laundering: new rules, new challenges. A far-reaching European package of measures was adopted to combat money laundering and terrorist financing. The package aims to reduce regulatory differences between EU Member States whilst better integrating international recommendations into national legislation. This book covers three key components of the legislative package: • the establishment of the new Anti-Money Laundering Authority (AMLA) • the new Regulation (AMLR) • the Directive (AMLD6) It brings these together – including the recitals – and provides in-depth insight into the implications for supervision, compliance, and practice. Authored by experts Birgit Snijder-Kuipers, Sari Eckhardt, Neyah Van der Aa and Juliëtte Boeser. 🔗 Link to the e-book in the comments. 👉 Essential reading for compliance professionals, supervisors, and legal practitioners navigating Europe’s evolving AML landscape. #AML #Compliance #EuropeanLaw #FinancialRegulation #MoneyLaundering #RegulatoryCompliance
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Important new research from John Heathershaw, Tena Prelec, Shayakhmet Tokubayev, and Tom Mayne, published in Europe-Asia Studies, sheds light on how Londongrad circumvented the UK’s anti–money laundering regime through a combination of political incumbency and the influence of professional enablers. Drawing on a dataset covering £2 billion of UK property purchased by politically exposed persons from Russia and Eurasia (1998–2020), the authors demonstrate that even with beneficial ownership transparency, entrenched networks of power and expertise can shield kleptocratic wealth from accountability. Their findings underscore a critical policy lesson: tackling kleptocracy in Britain demands more than sanctions and transparency—it requires real enforcement capacity and a reframing of the legal approach to recognise the systemic role of enablers. Read the open-access article here: https://lnkd.in/gQwGwKKq
Tena Prelec Shayakhmet Tokubayev Tom Mayne and I have published new research in the academic journal Europe-Asia Studies. In it, we show how Londongrad beat the UK Anti-Money Laundering regime via the incumbency advantage (political elites being in power or in favour back home) and enablers effect (networks of highly-skilled legal and financial professionals). Even when beneficial owners and their corrupt sources of wealth are made public, incumbency and enabling mean that kleptocratic networks can avoid accountability. The article is "open access" - free to all. The paper is based on our research now hosted by Centre for the Study of Corruption (CSC) and a database of £2 billion of UK London property purchased by politically exposed persons from Russia and Eurasia between 1998-2020, initially published by Chatham House in our report The UK's Kleptocracy Problem (December 2021). Thanks also to UK Aid for funding this research and to our fellow travellers in UK Anti-Corruption Coalition who have done similar work focusing on the role of professional enablers. The big takeaways for current policy debates are: 1) kleptocracy in Britain is not a "Russia problem" which can be sanctioned away; 2) transparency is not enough without a step change in enforcement capacity. The latter requires not just more resourcing of law enforcement but a conceptual change in law to recognise professional enablers as part of "kleptocratic enterprises" (a point we make in a #GIACE paper which will be out by the end of the year). https://lnkd.in/dN3cH5RS
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