The first UK National Action Plan for Anti-Money Laundering. Concrete progress towards making the UK a hostile environment for money launderers.
Fri 03 Jun 2016
Annual global illicit money flows are counted in trillions of US dollars and the new UK Anti-Money Laundering (AML) Action Plan is a part of the international ‘direction of travel’ in tackling money laundering. “The international community has made the fight against money laundering and terrorist financing a priority,” notes the International Monetary Fund (IMF).
Consecutive EU Money Laundering Directives have broadened the scope of sectors of business captured by the AML regulations; and increased the breadth and depth of requirements to manage the risk of businesses being used to facilitate money laundering.
Following the recent terrorist atrocities in France and Belgium, and a recommendation from the Financial Action Task Force (FATF), the EU is to bring forward the timetable for member states to implement the recommendations of the latest Money Laundering Directive.
The Panama Papers have revealed to all how global money laundering can be conducted and, in particular, can be aided by those based in financial centres such as London. London is the largest global centre for cross-border banking and UK efforts to manage AML risks are central to the international effort.
Although no reliable statistics exist of the amount of money laundered in the UK, the Director General of the National Crime Agency (NCA) has repeatedly stated that the figure runs to “many hundreds of billions.” In its most recent serious and organised crime threat assessment the NCA states, in relation to money laundering, “its sheer scale presents a strategic threat to the UK’s economy and reputation.” The latest NCA report on Suspicious Activity Reporting (SAR) shows a continued increase in SARs reporting.
The UK AML regime was recently reviewed by the IMF and in 2017 the UK AML framework is due to be further reviewed by FATF. In 2015 the government published the first UK national risk assessment of money laundering and terrorist financing.
The Directors of the Financial Conduct Authority (FCA), National Crime Agency and Serious Fraud Office have all indicated an intention to enhance general enforcement efforts, with the FCA, in particular, focussing upon enforcement to provide a ‘credible deterrence’ to money laundering. In May the FCA published its report on the de-risking phenomenon which has swept the banking sector over the past few years. The report attempts to bring balance to the fight against money laundering.
Very recently the Prime Minister announced the creation of a multi-agency taskforce, with substantial new funding, to tackle economic crime, including money laundering.
It is against this international backdrop that the UK government has published, in April 2016, its first AML Action Plan along the lines of the Anti-Corruption Action Plan published in 2015. The AML Action Plan has four themes:
Even if the government only succeeds in implementing some of the 19 action points contained within the four themes, the UK will become a little harder for the corrupt and dishonest to clean their stolen trillions.
The European Union Development Days bring together the development community each year to consider and exchange ideas on enhancing international development efforts. The theme of the two day event in Brussels in June this year, was the UN Sustainable Development Goals (SDGs) in action. The event attracted high level delegations from donors and the developing […]
Corruption is “the greatest enemy of progress in our time” said Sir Eric Pickles, the UK Anti-Corruption Champion during his keynote speech at the OECD Integrity Week in Paris in April. The focus of the OECD Integrity Week this year was “Global Trade without Corruption” and I was honoured to be invited to be a […]
“PIDA is dangerous for whistleblowers because people think they have stronger protection under it than they actually do”. – Lord Touhig, co-author of the Public Interest Disclosure Act.
Within a raft of proposals, commitments and promises announced during the London Anti-Corruption Summit on 12 May 2016, was a proposal to consult on holding companies to account for failing to prevent economic crimes committed by those they control. The idea has been floated a number of times over the past few years, not least […]
Earlier this month, on the eve of the publication of a new International Standard in bribery risk management, I joined a panel debate on the value of anti-bribery programme certification, hosted by Ethic Intelligence at the OECD in Paris. The event was attended by a number of eminent counter-corruption experts and provided a rare opportunity […]
To mark World Mental Health Day, Mazars Partner Tom Brichieri-Colombi shares his personal experience of stress in the workplace. In June of this year, AccountancyAge published an article entitled: What we have learned about mental health at work, highlighting the results from its 2018 survey on this topic. The top two findings from the report […]
Recent corporate scandals, and their impact on share prices, have focused many minds on how to avoid recurrence. Much of the coverage has focused on the culture which allowed this to happen, yet while there is widespread agreement that culture can be pivotal to how the board and employees behave, the conversation often stops at […]
The world of financial crime risk management is changing fast with the most innovative organisations exploring behavioural sciences to provide deeper insight into mitigating the risk of misconduct. The criminal prosecution of corporate misconduct is also going through some fundamental changes. In February 2015 the American concept of a Deferred Prosecution Agreement (DPA) was added […]
The 2015 Corruption Perceptions Index (CPI) that ranks countries by the perceived level of public sector corruption, was published by Transparency International on 27 January 2016. The CPI has many detractors but is, nonetheless, read attentively by governments, companies and interested individuals around the world. One of the interesting facts about this year’s results is […]
You won’t find human rights on any profit and loss account codes of company trial balances; well I haven’t seen any in my 25 plus years as an auditor. And indeed, why should I have seen this? What, after all, does human rights have to do with business?
This chart shows the five year performance of the FTSE4Good UK and the FTSE All-Share indices. Over five years the FTSE4Good UK Index has outperformed the FTSE All-Share Index by 3.49%. What does it tell us? That over time it is possible for ethical investments to outperform traditional investments. Each index has different requirements for company […]
In 2012 and 2013, “human rights audits” took place at two garment manufacturing factories: one at Ali Enterprises in Pakistan, the other at Tazreen Fashions. Weeks after both “audits” took place, over 400 workers’ lives were lost due to fires at the factories. Social, or human rights, auditing was in the spotlight. After all what […]
In my previous blog, I discussed the international influence the United Nations Guiding Principles on Business and Human Rights (UNGPs) has had, and continues to have, on ensuring companies respect human rights and the unparalleled support across nations.
After three years of hard work the new International Standard in bribery risk management is nearly ready. Following the success of British Standard 10500, the Anti-Bribery Management System (ABMS), in 2013, the International Standards Organisation (ISO) approved the development of an ISO Anti-Bribery Management System.
On 25 September 2015, at the United Nations General Assembly over 150 world leaders adopted the Sustainable Development Goals (SDGs); all 17 of them, with 169 sub-targets to be achieved by 2030. They cover most of the laudable aims that any sensible person who wants our society to thrive and survive on this planet for […]
Corporate respect for human rights is a critical part of any business’s success and future prosperity. It’s not only about brand protection, it’s also about brand enhancement. But in a complicated environment, what steps can you take to ensure your company is complying with its human rights responsibilities? 1. Set the right tone at the […]
Celebrating #WomenAtMazars – Rebecca Dacre Next in our Celebrating #WomenAtMazars series, we’re speaking to Rebecca Dacre, a Director in the Restructuring Services Team, based in Milton Keynes. Don’t forget to catch up with the previous interviews in this series with: Iris Hughes, Senior Internal Auditor, Consulting Charlene Nunn, Senior Manager, Audit and Assurance Harriet […]
For several years the Serious Fraud Office has been preaching an extension of the strict corporate liability provisions contained within Section 7. This would create liability for companies that fail to prevent other forms of economic crime, such fraud and market manipulation. Those who follow my blogs will know that I, too, am a strong […]
The below letter appeared in Letters to the Editor, Financial Times, 10 January 2018. Find the original piece here. Dear Sir, Your leader entitled “A better deal between business and society” (January 2) is very timely. You primarily focus on the role businesses — and in practice their boards — need to play in strengthening […]
Today is International Women’s Day, and to show our support for this year’s theme; #PressforProgress; we’re taking the opportunity to celebrate the achievements of women from across Mazars. Over the coming weeks, we’re going to be hearing from women in the firm about their careers, how they’ve progressed and what they’ve learnt along the way. […]
Over the coming weeks, we’re going to be continuing our celebration of the achievements of women from across Mazars as part of our commitment to #PressforProgress. In the first interview in our Celebrating #WomenatMazars series, we spoke to Helen Parker, a Director in the Entrepreneurial Business team. This week, we’re hearing from Charlotte Ward, an […]
Find out what keeps her motivated, what has been the most defining point in her career to date and the advice she would give her younger self. Don’t forget to take a look at the previous interviews in this series with Helen Parker and Charlotte Ward. Hi Jennifer, can you tell us a bit […]
Celebrating #WomenatMazars – Sophie Mellor Next up in our Celebrating #WomenatMazars series we’re speaking to Sophie Mellor, a Tax trainee who is part of the Tax Advisory team based in Milton Keynes. Sophie tells us about her career path to date, from gaining work experience whilst she studied at university to her current role […]
Celebrating #WomenatMazars – Catherine Hall Next in our Celebrating #WomenatMazars series, we’re speaking to Catherine Hall, an International Tax Partner who is based in London. Catherine has worked in a variety of roles over the course of her career. She shares how having a strong support network has been key to overcoming challenges, and […]
Celebrating #WomenatMazars – Lara Brennan This week in our Celebrating #WomenAtMazars series, we’re joined by Lara Brennan, a Senior Manager from the Financial Outsourcing and Advisory team, based in Poole. Don’t forget to catch up with the previous interviews in this series with: Helen Parker Director, Entrepreneurial Business Charlotte Ward Assistant Manager, Forensic & […]
Celebrating #WomenAtMazars – Harriet Walker Today in Celebrating #WomenAtMazars, we’re sitting down with Harriet Walker to find out more about her life and career at Mazars. Harriet is a Corporate Assistant in the Professional Practices team in Edinburgh. Don’t forget to catch up with the previous interviews in this series with: Catherine Hall, International […]
Celebrating #WomenAtMazars – Charlene Nunn This week’s edition of Celebrating #WomenatMazars, we’re speaking to Charlene Nunn, a Senior Manager in the Audit and Assurance team, based in Manchester. Don’t forget to catch up with the previous interviews in this series with: Harriet Walker, Corporate Assistant, Professional Practices Catherine Hall, International Tax Partner Lara Brennan, […]
Celebrating #WomenAtMazars – Iris Hughes Next in our Celebrating #WomenatMazars series, we’re speaking to Iris Hughes, a Senior Internal Auditor in the Consulting team, based in London. Don’t forget to catch up with the previous interviews in this series with: Charlene Nunn, Senior Manager, Audit and Assurance Harriet Walker, Corporate Assistant, Professional Practices Catherine […]
In yet another financial scandal, record fines were announced for six international banks involved in forex rate fixing, despite the not-dissimilar prior Libor scandal. A day later the CEO of the FCA, Martin Wheatley, was reported as saying that fines were having an effect on board culture in the City. But it’s not just banks […]
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