The Dark Money Files

In this second part of our review of recent fines against SEB in Sweden and Commerzbank in the UK we dive into the detail of the Commerzbank Final Notice which reveals one or two surprises! Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thedarkmone...

In this episode we begin our review of the Commerzbank fine by the FCA and give a brief overview of the SEB fine by the Swedish FSA. What can we learn from these events? Have a listen to find out! Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thed...

In this episode we review the recent report by David Leask and Richard Smith published on the OpenDemocracy website revealing the current state of play with respect to the UK Person with Significant Control regime. We use the opportunity to summarise the reasons for, and the requirements of the regime. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-...

In this episode we cover the foundations of trade based money laundering, what it is and how, classically, it is done. Along the way we make some surprising price discoveries on Amazon, compare a pair of tweezers to the size of a hydrogen atom and discover an unlikely candidate for dual use goods. Link to the John Zdanowicz TBML research: https://www.researchgate.net/publication/46556338_Trade-Bas...

This week we look at the impact of the coronavirus on bank's financial crime controls, processes and systems. We also give an update on the Dark Money Files Conference which is still going ahead as planned in September, although in a different format! Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://tw...

Part two of a two part episode reviewing and commenting on the recommendations contained in the recent European Banking Federation's review of the role that banks need to play in the fight against dark money.  Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at...

Part one of a two part episode reviewing and commenting on the recommendations contained in the recent European Banking Federation's review of the role that the banks need to play in the fight against dark money. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website...

A short episode announcing the birth of "The Dark Money Files Live Online". We're just finalising the right platform, material and timings and subscriptions will open shortly. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thedarkmon...

Following the release of the Clifford Chance report into Swedbank's High Risk Non Resident portfolio (HRNR) in the Baltic States, we have recorded a special episode based on our initial review of the Executive Summary of the report. In our opinion it mostly makes for "ugly reading". Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-...

In this episode we return to the theme of effectiveness, stick up for Deutsche Bank, prefer the Avengers over Batman and announce our forthcoming Dark Money Conference. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thedarkmoneyfiles.com/

In this episode we look at the effectiveness of AML control frameworks, what we might mean by effectiveness, the use of fines and the onset of compassion fatigue, We also announce the forthcoming Dark Money Conference about which we will be saying more in our next episode. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitt...

In what is probably the most important episode we've recorded to date, we talk about the way in which money laundering is reported and the potentially sexist narrative that underpins it. We also talk about how the frame of reference which the general public forms in relation to money laundering can be altered (for better or worse) by the manner of that reporting. Send us Fan Mail Support the...

In this episode we look at the recent proposed defamation case between Javanshir Feyziyev and the OCCRP and the role that The Dark Money Files played (so far as we are able to talk about it) in the lead up to the case (which never actually went ahead).  Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitt...

In this special episode to launch Season 4 we look at the newly revamped FCA - Financial Crime Guide and decide that it is an invaluable tool for financial crime professionals wherever in the world they might work. We also take a look at confirmation bias and how it can contribute to less than effective outcomes. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/c...

In this last episode of season 3 we turn our attention to conducting the business (or enterprise) wide risk assessment. Why and how figure prominently. We also look at the main elements of the soon to be introduced (as at 08/10/2020) Money Laundering and Terrorist Financing (Amendments) Regulations 2019. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/th...

In this second part of assessing customer risk, we look at the impact of delivery channel, products, entity type and industry on the overall risk rating. We talk about the changes that new technology have had on verification of ID and how different firms need to tailor their risk assessment to their own product and demographic range prior to addressing the firm wide risk assessment in our next epi...

This week, after a brief review of the latest OCCRP stories (called #29leaks) we turn our attention to the thorny issue of customer risk assessments, starting with a focus on country or jurisdictional risk. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https:...

We take a close look at events reported by SVT (Swedish Television) in relation to SEB's non-resident banking in the Baltics. Based on leaked material which has been shared with us, we include a forensic review of the detailed statement carried on their website and conclude that their are areas which still leave room for concern. Send us Fan Mail Support the show Follow us on LinkedIn at http...

In this episode we complete our look at PEPs by going into Enhanced Due Diligence in a bit more detail before turning our attention to other high risk situations.  Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thedarkmoneyfiles.com/

In this episode we talk all things PEP. We cover how to define one, what constitutes a relative or close associate, what is the difference between source of wealth and source of funds and the thorny issue of PEP retirement or declassification. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dar...

In this episode we look back at a recent episode of the BBC1 news programme "Panorama" featuring drug money, gold bullion, billions of dollars of money laundering, poor treatment of whistle-blowers and a (very brief) appearance from one half of the duo. We talk about the money laundering "process" and how the description could be improved and look ahead to a forthcoming mini-se...

This week we look at two separate issues (but there are similarities).  First up, Swedbank published its 3rd quarter results this week and included an update on their ongoing investigations into the alleged use of their bank as part of a money laundering operation in the Baltics. Secondly, we revisit the recent FATF plenary in Paris and put forward our own proposals for how we think the Mutual Eva...

This week, in honour of the first 2019 Plenary meeting of the FATF we look at the birth of the organisation in Paris in 1989 and a pillar of its existence - The Mutual Evaluation Report. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thedarkmoneyfi...

In this episode we look at the recent raid on Deutsche Bank in connection with the Danske Bank story, the role of correspondent banking in the story and the risks associated with it. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at  https://www.thedarkmoneyfiles....

In this episode we take a long hard look at the reporting requirements and all the other responsibilities placed on the Money Laundering Reporting Officer. We look at an example of what can happen when thing go wrong but also the huge variety of challenging but interesting and important jobs the MLRO is responsible for. Send us Fan Mail Support the show Follow us on LinkedIn at https://www.linkedi...