The Londoner

Payable Through Accounts (PTAs) can introduce certain Anti-Money Laundering (AML) risks due to their nature as conduits for cross-border transactions . AML refers to the set of regulations, laws, and procedures aimed at preventing and detecting activities related to money laundering and the financing of terrorism . Here are some potential AML risks associated with PTAs: 1. Lack of Visibility:   PTAs involve transactions that may not be directly visible to the beneficiary bank or financial institution. This lack of transparency can make it more challenging to identify suspicious activities or patterns that may indicate money laundering. 2. Layering :  Layering is a technique used by money launderers to obscure the origin of funds by conducting a series of complex transactions . PTAs can be used to facilitate these layered transactions , making it harder for authorities to trace the source of funds . 3. Rapid Movement of Funds :  PTAs can facilitate rapid movement of fun...

The United Arab Emirates (UAE) has implemented several measures to comply with anti-money laundering (AML) regulations and combat the financing of terrorism (CFT) .  1. AML Law and Regulations : The UAE has established specific laws and regulations to combat money laundering and terrorist financing. These laws define various offenses related to money laundering and prescribe penalties for non-compliance. 2. Designated Authority : The UAE has designated a competent authority responsible for overseeing AML/CFT efforts and ensuring compliance across the financial sector. The authority may vary depending on the emirate or the type of financial institution. 3. Customer Due Diligence (CDD) : UAE's AML regulations require financial institutions and designated non-financial businesses and professions ( DNFBPs ) to conduct customer due diligence before establishing a business relationship. This includes verifying the identity of customers, beneficial owners, and understanding the nature of...

FCG provides practical assistance and information for firms of all sizes and across all FCA-supervised sectors on actions they can take to counter the risk that they might be used to further financial crime. Its contents are drawn primarily from FCA and FSA thematic reviews , with some additional material included to reflect other aspects of our financial crime remit. Effective systems and controls can help firms to detect, prevent and deter financial crime. FCG provides guidance on financial crime systems and controls, both generally and in relation to specific risks such as money laundering, bribery and corruption and fraud. Annexed to FCG is a list of common and useful terms. ■ FCG Annex 1 is provided for reference purposes only and is not a list of ‘defined terms’. Where a word or phrase is in italics, its definition will be the one used for that word or phrase in the Glossary to the FCA Handbook . FCTR provides summaries of, and links to, FSA (now the FCA) thematic reviews of va...

Tens of billions of dollars every year move through opaque law-firm bank accounts that create a gap in U.S. money-laundering defences , according to a Wall Street Journal analysis. These accounts were used by suspects in a multibillion-dollar scandal involving a Malaysian state investment fund known as 1MDB , according to a Justice Department description of events. They also played a part in  a Florida Ponzi scheme , in a case related to an  official of Equatorial Guinea  and in a dozen other U.S. money-laundering cases over the past decade, case records show. Law firms lump together client money they are holding for short periods, such as while real-estate sales are pending, into pooled bank accounts , and the law firms face no requirement to disclose whose cash is in the accounts. Banks say they generally see only a law firm’s name. Money often stays in the accounts for only a few days or weeks. At the request of law firms’ clients, funds can be se...

By Sikander Hayat  Before we start to have a look at the KYC requirements for a Trust, we need to understand some basics about this entity type. 1.       What kind of legal entity is a Trust 2.       How many kinds of common Trusts structures are there 3.       Who normally use Trust entities and 4.       From Money Laundering point of view, what are the major risks From money laundering point of view, Trusts can be a very tricky type of entity as it can be structured in such a way to avoid detection of real beneficiaries . Trusts can also be used as avehicle for tax evasion . Trusts can be set up in jurisdictions which are very opaque and make it difficult for any law enforcement agencies or counterparties to be sure of who is actually behind the trust.  We also need to watch out for situations where: 1.       The c...

Central Banks are not a very difficult entity to on-board as a counter party because risk based approach will suggest that it is one of the least risky proposition if done correctly. Here are the main steps to perform counterparty check on a Central Bank: 1.        Check on Bank for International Settlements (BIS) that it listed on that website.  The name should match exactly and link should take you to your potential counter party’s website.  The website link for BIS is https://www.bis.org/ .  This is the confirmation that your counterparty is a central bank. 2.        Get the proof of existence and name. This can be achieved by using central bank’s website and Bankers Almanac. Bankers Almanac is an acceptable source for most banks. The link to their website is https://www.bankersalmanac.com/formslogin.aspx# This is not a free resource and your organization will have to pay for this webs...