Send us a Text Message. 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 Support the …

Send us a Text Message. 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. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/…

Send us a Text Message. 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/ Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-mo…

Send us a Text Message. 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…

Send us a Text Message. 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. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at htt…

Send us a Text Message. 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. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at https://twitter.com…

Send us a Text Message. 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. 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 http…

Send us a Text Message. 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. 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…

Send us a Text Message. 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. 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 w…

Send us a Text Message. 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). Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/t…

Send us a Text Message. 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. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at https://tw…

Send us a Text Message. 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! Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at https://twitter…

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

Send us a Text Message. 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. Support the Show. Follow us on Linked…

Send us a Text Message. 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 frau…

Send us a Text Message. 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! 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 htt…

Send us a Text Message. 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. 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…

Send us a Text Message. 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. 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_f…

Send us a Text Message. In this episode we look at the thorny issue of Management Information. What is it and what’s it for. Simple questions you might think, but often overlooked. 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 …

Send us a Text Message. In this episode we bring you an update about regulatory expectations in respect of cash deposits. Along with a brief history of the UK’s Post Office dating back to the 17th century and the somewhat surprising news that it is still possible to make unlimited daily cash deposits of up to £20,000 with no form of identification.…

Send us a Text Message. In the first episode of season 10, we turn our attention to an extraordinary story about online retail sales, China, VAT and HMRC. Despite all the apparent jargon, it is just an everyday tale of 11,000 companies all suddenly deciding to register to a private address where the owner had never heard of them. Which didn’t stop …

Send us a Text Message. In the second part of our look at multiple choice tests we talk about how some fairly basic statistical analysis can help to validate their effectiveness. 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 ht…

Send us a Text Message. Does your assessment programme correlate to individual performance? And if not, why not? Part one of a journey on the road to cognition. 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.thedarkm…

Send us a Text Message. In this episode we talk about using our (metaphorical) little yellow bird as a predictor of the overall effectiveness (or lack of it) of your anti-financial crime framework. Would your KYC fall off its perch at the first whiff of trouble? Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-mo…

Send us a Text Message. In this episode we work through three of the smaller regulatory actions from last year which nevertheless contain nuggets of gold, successfully panned by Ray. 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…

Send us a Text Message. In something of a departure from our normal content, we review the passage of the Economic Crime and Corporate Reform Bill through the UK parliamentary system and use the opportunity to explain in more detail just how the scrutiny and passing of legislation works in practice. Support the Show. Follow us on LinkedIn at https:…

Send us a Text Message. In this episode we weave together crypto, courts and controversy when Sam Bankman Fried meets the Court of Justice of the European Union and a millionaire underwear Baroness. 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 s…

Send us a Text Message. It’s been a little while so we thought we’d do a bit of a catch up on some recent publications from Wolfsberg, the FATF and the Finnish FSA. 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…

Send us a Text Message. In our final part of our look at fraud, we explain, in general terms, current approaches to how best to compensate the victims and deny the fraudsters (as well as explaining briefly, why the gap since the last episode). Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on T…

Send us a Text Message. We interrupt our suite of podcasts on fraud to bring you a special episode relating to the human cost of fake company incorporations. Working with various different media outlets, we’ve helped bring to light some of the stories relating to people who unwittingly fall foul of fake company incorporators. Listen, for example, t…

Send us a Text Message. In this second part of our series on fraud we delve into some of the different types of fraud. We proffer some “mildly salacious” examples, along with others which are rather more serious. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at https://twitter.com/d…

Send us a Text Message. In this pun laden episode, we start to delve into the world of fraud. More to follow… 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/…

Send us a Text Message. The UK regulator, in common with most regulators around the world, is keen to understand the role that synthetic data might play, alongside Artificial Intelligence and Machine Learning. It has made a call for input which closes on 22 June. In this episode we review the current state of play, the uses for synthetic data and w…

Send us a Text Message. In this episode we tackle the thorny issue of tax avoidance, aggressive tax avoidance and tax evasion. We also take a closer look at one of the schemes which falls somewhere on that spectrum: mini-umbrella companies. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twit…

Send us a Text Message. In this episode we look at all things digital and how it is changing the landscape of authentication whilst making KYC more dynamic. 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.thedarkmoney…

Send us a Text Message. To conclude this trilogy of podcasts looking at the world from the money launderers point of view, Ray and Graham take a deep dive into trade-based money laundering and trade finance. They revisit the research conducted by John Zdanowicz – copy of the report referred to can be found here. $5000 tweezers and enriched uranium …

Send us a Text Message. In this second part of Graham & Ray’s trip to the dark side, and with almost prescient timing, they explain how to set up a global money laundering machine. Please don’t try this at home. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at https://twitter.com/da…

Send us a Text Message. Having spent three years and 93 episodes reporting from the side of the great and the good, Ray and Graham move the focus to the view from the dark side. And it sounds like they had an inordinate amount of fun doing so! Two more parts to follow! Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-…

Send us a Text Message. We bring this trilogy of episodes around transaction monitoring failures to an end with a final review of the NatWest case and a comparison with the recent fine levied against HSBC. What’s that got to do with a King, his cleaner and a thirsty aspidistra? You’ll need to listen to find out! Support the Show. Follow us on Linke…

Send us a Text Message. In this episode we bring you the second part of our deep dive into the criminal prosecution of NatWest through the lens of the Statement of Facts which accompanied the guilty verdict. This time, amongst other things, we cover smelly banknotes and bin bags full of cash. Support the Show. Follow us on LinkedIn at https://www.l…

Send us a Text Message. In this episode we bring you part one of a deep dive into the criminal prosecution of NatWest through the lens of the Statement of Facts which accompanied the guilty verdict. No matter where you are in the world, given the ubiquity of AML regulations, this will be relevant to you and your organisation. Support the Show. Foll…

Send us a Text Message. In this episode we want to move away from always being suspicious and look at the other side of the coin. Can we use green flags to help identify suspicious behaviour from a very different angle? And do we need to be cautious in our use of whitelists? Support the Show. Follow us on LinkedIn at https://www.linkedin.com/compan…

Send us a Text Message. In this episode we enthusiastically review the new advanced search function recently launched on the Companies House website. We also make a heartfelt plea for other corporate registers to look and learn from the huge potential gains in proactively managing corporate financial crime risk that it facilitates. Support the Show…

Send us a Text Message. In this episode we look at how the FCA’s REP-CRIM report can assist firms in assessing the effectiveness of their AML controls through both trend analysis and benchmarking against their peers. And we explain how trend analysis such as this can benefit all financial institutions wherever they do business. Support the Show. Fo…

Send us a Text Message. In this episode we review the need for firms to review, and adjust as necessary, their financial crime control environment. We also talk about some of the triggers which might cause these adjustments and the actions which might follow. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money…

Send us a Text Message. In this episode we give our views on the Pandora Papers and some of the broader considerations which might flow from their release. 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.thedarkmoneyf…

Send us a Text Message. Remediation programmes are becoming an all too frequent feature of life for financial crime compliance departments, so we we’ve put together a summary of good practice, do’s and don’ts and other things to consider when embarking on such a course of action. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/c…

Send us a Text Message. Sometimes you just have to go back to basics. And this week it's risk. Does low risk equal no risk? Is all risk equal? Should you ever do EDD on a low risk customer? We answer these questions and many more. Support the Show. Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at htt…

Send us a Text Message. In this episode we wander away from traditional banking intro the world of informal value transfer systems. Oh, and we look at the price of missile launchers. But you’ll need to listen to understand why! Link to the TBML paper written by John Zdanowicz https://www.researchgate.net/profile/John-Zdanowicz/publication/46556338_…

Send us a Text Message. Occasionally, we record an episode which is truly an exclusive, and this is one of them. This episode started life as a straightforward explanation of the use of art and auctions in money laundering schemes. And then it went off on the most unexpected and jaw dropping tangent. You’ll need to listen to understand how art, auc…