The Dark Money Files

In a slightly longer than normal episode we do a deep dive into partnerships of various flavours and how the Economic Crime and Corporate Transparency Act is going to change things.

Partnerships are not straightforward (hence the longer episode) but they are sensitive to abuse so this is an important topic for financial crime professionals.

And there is the offer of a free gift at the end of the episode!

What's not to like.

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We take a look at the effect of human behaviour on our ability to stop criminals gaining access to the financial system and why that system is more likely to produce comprehensive documents than effective detection.

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We look at the role of Authorised Corporate Service Providers (ACSPs) in the new regime at Companies House and explain why understanding both its strengths and weaknesses is important to anyone responsible for onboarding or monitoring UK companies, wherever in the world you work.

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One for the geeks! 

Changes in company formation levels are often use to justify/criticise different governments' economic policies.

We go behind the headline figures to see if this is justified or not (HINT: not!).

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Ten years after the creation of the Office of Financial Sanctions Implementation, we look at how the UK sanctions regime has evolved—from early uncertainty to strict liability enforcement, sanctions list complexity, and the growing expectations on the private sector. 

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Today we tackle some colourful risk lists or, to be a bit more precise, some black and grey ones, along with some strange differentials. 

Like how come the UK has a high risk third country list when there are no second countries in sight?

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In the second of a two part, end of year podcast, we continue to explain how we helped with a major BBC investigation into crime on the high street, involving the sale of illicit cigarettes and vapes, modern human slavery, people trafficking, tax evasion, corruption and money laundering.

In this episode, undercover filming unearths a shocking story and we explain our part in finding some of the protagonists involved.

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In the first of a two part, end of year episode, we explain how we helped with a major BBC investigation into crime on the high street, involving the sale of illicit cigarettes and vapes, modern human slavery, people trafficking, tax evasion, corruption and money laundering.

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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/

We examine two recent final notices issued by two different regulators relating to two quite different enterprises and find a surprising amount of commonality in their thinking.

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In the first of a new, occasional series, in which we sit down and chat to fellow anti-financial crime professionals, we kick off with Marit Rødevand from Strise to talk about AI and other new fangled gizmos.

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The UK Insolvency Service does a lot more than just oversee insolvencies and, in a recently published five year strategy document, they outlined some ambitious future goals which we thought were well worth a conversation.

So we had one!

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The FCA recently published new guidance specifically in relation to UK PEPs which we decided needed a closer look. So we did!

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In this episode we explain how we supported a major BBC investigation into a Hungarian organised crime group which was systematically forging wills and stealing the assets belonging to the estate from under the noses of the true beneficiaries.

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In this episode, we chat about a recently published report by Transparency International (see: https://www.transparency.org.uk/news/trust-issues-tackling-final-frontier-secret-property-ownership) and how it impacts on our ability to identify the true ownership of real estate in the UK (and elsewhere).

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We bring you our latest deep dive into the world of crazy company incorporations and weird worldwide coincidences by way of North London, New Zealand and a much loved British sit-com.

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SARs!

Search and rescue services?

Subject access requests?

Sudden acute respiratory syndrome?

No - suspicious activity reports! That's what we are talking about this time. And there's a lot more to them than you might think.

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In this episode we look at the FCA's latest thematic review of the National Fraud Database and money mule account detection tools and summarise what we think firms can take from it and what actions they might consider taking in response.

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"...Because every day we pay the price, we’re the living sacrifice"

Taking inspiration from Bob Marley (sorry about the pun) we've done a little episode about scams and scammers (and some hints on how to spot them).

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In this episode we look at some of the links between three recent enforcement actions.

We try to avoid the knee jerk reactions, and think a bit deeper about them.

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We turn our attention to the requirement to train relevant staff on all matters anti-financial crime.

And if you're planning on training - your training needs a plan!

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In this episode we turn our attention to the tricky subject of outsourcing. We were going to get someone else to do it for us but we couldn't find a suitable candidate. :)

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Hot spots and intelligence 2

In this second episode we look more broadly at the genesis of intelligence led policing, how it works and how compelling it is to draw parallels with our world of anti-financial crime.

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In this episode we report on a recent visit to the European Crime Analysis conference in Copenhagen and draw parallels between the work of law enforcement and those working in compliance.

Links referred to in the episode:
Hot spot policing
Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity

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In this episode we explore some of the many different ways in which corporate entities can be used to engage in financial crime – although, as far as we are aware, they aren’t much use in removing stones from horse’s hooves.

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We dive into the details of OCGs and how they use corporate networks to launder their ill-gotten gains - and the clues they leave behind.

And, rather appropriately, we also introduce the world to our new sponsor: https://riskalert247.com/

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In this episode we turn our attention to the thorny subject of proliferation financing and provide a basic explainer of what it's about and why it's important.

The documents referred to in the episode can be accessed via the links below:

 FATF Guidance on PF risk assessment | https://bit.ly/4a9FKTM
 UK National Risk Assessment of PF | https://bit.ly/3JP2Lk7
| RUSI paper on PF in banking | https://bit.ly/4b4JpTU
| European Commission guidance for EU operators | https://bit.ly/4doVhSr

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With a forthcoming new requirement which makes it mandatory for UK payment service providers (PSPs) to reimburse the victims of some types of fraud, we look at the rules and how they are likely to play out.

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Taking a slightly different direction from our normal content, we step back and look how the landscape of crime has changed over the years, and how in the process it has become democratised.

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Following the news that nearly 800 restaurants in the UK have been cloned over the last few weeks, we thought we’d bring you the story behind the story. 

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It’s over to EU

After a succession of episodes looking at the UK financial crime landscape, we shift our focus over the channel to Europe and the proposed changes to EU AML legislation.

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Following some recent banking shenanigans, there’s been a rapidly introduced change in the UK law relating to PEPs.

We think it needs to be put into a global context.

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In this second part of our review of the Economic Crime and Corporate Transparency Act, we look at the provisions relating to  failing to prevent fraud, crypto assets, information sharing and Strategic Lawsuits Against Public Participation (SLAPPs).

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Following the enactment of the Economic Crime and Corporate Transparency Act, reform is on the way to Companies House.

But what does it look like and when will it happen?

Here's our initial overview.

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In this episode we walk the path from certainty to impossibility, via probable, possible and plausible.

A conversation involving wind turbines, zebras and UFOs.

You need to listen to understand!

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In this second episode devoted to ultimate beneficial ownership, we delve into the world of exchange traded companies and the esoterica that is trusts.

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In this episode we, somewhat belatedly, begin to tackle the thorny issue of identifying ultimate beneficial ownership. 

And we do so by pointing out that the “ownership” part of UBO is a bit misleading because it doesn’t cover control or influence.

But then a UBOCI is a bit of a mouthful.

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In this episode we walk through a recent, in-depth report into probable VAT and employment tax fraud reported on by Dan Neidle of the Tax Policy Associates, in partiucalr, how various different proessionals, individuals both here and abroad, and social media websites can be used, wittingly or unwittingly, to further the fraudsters aims.

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We couldn't let the recent Farage brouhaha with Coutts go by without some sort of comment.

We've tried to chart a calm course through some choppy waters!

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In this episode we ask "What have the dinosaurs ever done for us?" 

It turns out, if you ask the right questions, it's quite a lot.

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In this episode we take a (hopefully) user-friendly trip down the statistical road and explore some of the common pitfalls that can be encountered in preparing management information.

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