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TitreDateDurée
Financial Crime Training - Mind the gap!14 Oct 202400:16:37

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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The (out)source code10 Sep 202400:15:18

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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It's over to EU07 Feb 202400:21:44

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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It's time for a PEP talk!11 Nov 201900:21:24

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.

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Panorama, Money Laundering, Whistleblowers and PEPS04 Nov 201900:17:00

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-series on "risk" starting with an introduction to the world of Politically Exposed Persons (PEPs).

We also announce the launch of our YouTube channel (https://www.youtube.com/channel/UCxQt-hM8EsoV-xLufUtY8Vw) and a significant upgrade to our website (https://thedarkmoneyfiles.com/) as well as a new "The Dark Money Files" venture - a "Serial" type podcast reporting on a detailed investigation in-depth. Due to launch in the New Year, the first season is provisionally titled "The Tower".

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Swedbank shines a light but FATF prefers privacy28 Oct 201900:16:06

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 Evaluation Report process could be improved.

Both demand to be looked at as much in the round as they do in detail.

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The feeling's mutual - The Financial Action Task Force and the Mutual Evaluation Report13 Oct 201900:17:39

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.

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The highs and lows of correspondent banking07 Oct 201900:18:45

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.

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The world of the MLRO30 Sep 201900:27:44

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.

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Looking back and looking forward24 Sep 201900:23:55

In this episode we reflect on some past episodes, chat about the recent Dark Money Files Live event and announce some exciting news for followers of the podcast.

New ways to bring you Dark Money stories!

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The EU Money Laundering Report09 Sep 201900:22:32

In this first episode of season three we give our listeners an overview of the report to the EU Parliament and Commission looking at recent money laundering cases in Europe and what we can learn from them.

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The Deutsche Bank Story, Part Four: The road to ruing11 Aug 201900:20:31

In this final episode of the Deutsche Bank story we look at the acquisition of Morgan Grenfell and Bankers Trust along with the banks somewhat strange relationship with Donald Trump. We also mention "The Dark Money Files Live" event which is coming soon to a location in London (with others to follow, we hope.

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The Deutsche Bank Story, Part Three: What the FCA found06 Aug 201900:21:04

In this episode we complete our review of Deutsche Bank's inspection by the FCA which led to them being fined £163m (and $425m by the Department of Financial Services - New York). W explain in some detail all of the areas identified for criticism but also highlight some of the good things Deutsche Bank did which don't always get the publicity they deserve.

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Are PEPs domestic?15 Jan 202400:17:06

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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The Deutsche Bank Story, Part Two - The FCA comes to visit28 Jul 201900:21:50

In this second part of our in-depth review of the recent travails at Deutsche Bank we talk about the background to the Systematic AML Programme (SAMLP) visit by the FCA, the  LIBOR fine which preceded it (including the £100m fine for DB's breach of Principle 11) as well as describing what exactly a SAMLP entails.

Whilst this is specifically a tool in the UK regulator's toolbox, the outcomes and learning from the visit would apply to any bank throughout the world.

We also mention the EU's latest report into the failings of some banks (including DB) in respect of recent alleged money laundering scandals.

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The Deutsche Bank Story: Part One - The Mirror Trades21 Jul 201900:25:32

Given its refusal to stay out of the news, we thought it was about time to turn our attention to Deutsche Bank. In an extended set of episodes we are going to examine in detail exactly what, in our opinion, went wrong and why.

Part one begins by examining the "mirror trade" affair in detail. We will bring to light previously unreported elements and also try and make sense of exactly what was the problem (HINT: It wasn't the mirror trades themselves).

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Extraordinary Danske developments and the need to report suspicions30 Jun 201900:25:47

We report on our involvement in recent leaks relating to Danske Bank and the potential criminal charges that can follow a failure to report. 

External reports commissioned and cancelled, suspicious activity detected but not reported and question marks over the way a whistleblower was treated. This episode has got it all!

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Old banks and new technologies - oil and water?23 Jun 201900:22:27

In this episode we start a conversation about FinTech and RegTech (along with a few digressions and diversions along the way). In an abbreviation heavy episode, we talk about face and voice validation, iris scanning and APIs, near field communication (NFC) chips and machine readable zones (MRZ) on passports and mention some of the ethical challenges that artificial intelligence and machine learning might pose. 

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Oh what tangled webs we weave!16 Jun 201900:18:25

Following on from our last episode looking at Bitcoin and the Blockchain, this week we look at the surface web, deep web and the dark web, explain what these different terms mean and then delve into the TOR network, TOR browser, .onion sites, the Silk Road and "Dread Pirate Roberts"!

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Bitcoin, Blockchain and Cryptography - Time to look forward02 Jun 201900:23:38

This week, with some trepidation, we embark on an overview of some of the more esoteric elements of financial crime risk management. We attempt to explain the blockchain, cryptocurrencies like Bitcoin, and cryptography generally, in layman's terms.

As neither of us are subject matter experts in any of these fields, we are somewhat laying ourselves open to rebuttal and ridicule but we felt it was worth the risk.

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Deutsche Bank's "Glitch" and Lithuania's "Pitch" - a week in AML27 May 201900:20:34

In this week's episode we talk about the glitch that was discovered in Deutsche Bank's transaction monitoring system (and a couple of other Deutsche Bank related news stories) as well as Graham's recent visit to Lithuania and their pitch to be a global centre for FinTechs (along with the fallout from the Troika Laundromat and much else).

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Laundromats and Legal Entities - part three: Scottish Limited Partnerships19 May 201900:19:34

The one you've all been waiting for! A detailed explanation of SLPs, their history, construction and how they are used to launder money - plus a further explanation of a Scottish Limited Partnership complex structure to show how they are evolving in the light of continued public exposure.

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The good, the bad and the companies - The Global Witness Report12 May 201900:18:35

In this special episode we review and comment on the recent Global Witness update to its reports from last year on the effectiveness of the Companies House PSC regime.

For more see:Global Witness blog and link

Oh, and we also include an amusing update to our previous report on UK Limited Liability Partnerships.

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Laundromats and Legal Entities - part two: Limited Liability Partnerships (LLPs)06 May 201900:25:33

In an extended episode, we delve into the intricacies of UK LLPs and, using real examples, explain how the rules allow them to be constructed in a such a way as to hide ultimate ownership behind a series of entirely plausible, but geographically diverse entities.

And our old friend Ali Moulaye gets a mention (or two...).

Due to the complexities of the subject, there are supporting graphics on our website.

DISCLAIMER: There is no suggestion by us, explicit or implied, that any of the people or entities discussed in this or any other episode of "The Dark Money Files" is in any way connected to laundromat or other criminal activity. They are simply used as examples of how other actors might circumvent the rules.

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ECCTA Part 2 - SLAPPS, Fraud, Crypto and information sharing30 Nov 202300:21:21

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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Laundromats and Legal Entities - part one: Limited Companies28 Apr 201900:22:54

We begin our analysis of how legal entities, in locations which have transparent corporate registers can still be used to mask ultimate ownership and control while still providing a veneer of respectability.

In this first part we look at Limited Companies and their Directors, Shareholders and Persons with Significant Control, to see how each of these can look plausible but still need further investigation.

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Ali Moulaye: The man, the myth and the method22 Apr 201900:21:56

In this first episode of season 2 we discuss Ali Moulaye, the man whose signature is at the base of Companies House account filings for a multiplicity of LLPs identified as being involved in a wide variety of laundromats. And it's quite a story!

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Episode 10 - The Whistleblower, the UK and the Russian connections07 Apr 201900:21:39

In a sensational final look at the Danske Bank affair, we analyse the whistleblower report and definitively link it to a UK LLP (along with a few others) a small Russian Bank with Igor Putin (cousin of Vladimir) on the board, the Deutsche Bank mirror trades, Alexander Perepilichnyy, Alexander Litvinenko, Ali Moulaye and a whole lot more.

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Episode 9 - Danske Bank: The bond loop and the intermediaries31 Mar 201900:22:16

In 2013 Danske Bank executives started to examine,rather more critically, the lucrative bond sale business in Estonia. We look at the reporting and decision making process at the start of that journey and wonder whether, in hindsight, they might have chosen to have done things differently. We also discus the risks of doing business with unregulated intermediaries (HINT: They are very high!).

The ultimate outcome of those initial investigations is really rather surprising.

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Special Episode 3 - The Swedbank/Forensic Risk Alliance Report Phase 122 Mar 201900:17:58

Following the release of Phase 1 of the Forensic Risk Alliance report prepared for Swedbank, we take a detailed look at that it has uncovered and where we'd like Phase 2 to go.

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Episode 8 - The Missed Opportunities17 Mar 201900:24:31

We begin to look at all the different occasions, highlighted in the Bruune and Hjejle report, where the management of Danske Bank could (and arguably should) have become aware that they had a significant problem in the Estonia Branch and taken much more assertive action to do something about it. 

In this episode we look at the years from 2008 to 2010.

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Special Episode 2 - The Troika Laundromat10 Mar 201900:18:52

The second of our special episodes looking this time at the OCCRPs newly released data dubbed "The Troika Laundromat". 

Rather than spend 20 minutes criticising everyone involved we thought we'd spend some time contextualising what it means and then look at how data releases like this can be put to good effect by helping the banks to improve their detection of financial crime in the future.

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Episode 7 - The Suspicious Activity Report (Part 2)03 Mar 201900:25:53

In this jaw-dropping episode we look under the bonnet at the situation in Estonia just after Danske had bought Sampo.

It highlights conflicting stories between what the Estonian regulator was saying to Danske (and in fact, ordering them to do) and what the bank was saying to the Danish regulator.

It also looks in detail at the apparent discrepancies between what they had been ordered to do and what they carried on doing.

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Special Episode 1 - The Ousting of Danske and the Arrival of Swedbank23 Feb 201900:20:31

Following an extraordinary week of developments which saw the removal of Danske from Estonia, its voluntary departure from Latvia, Lithuania and Russia, the launching of an investigation of both Danish and Estonian regulators by the European Banking Authority, the prolonging of an argument between the two regulators by the publication of hitherto private correspondence AND the addition of Swedbank to those embroiled in the laundromat, we've recorded a special episode to talk about all these developments.

And what developments they have been!

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Episode 6 - The Suspicious Activity Report (Part 1)18 Feb 201900:26:17

In this episode we begin to look at the report, commissioned by Dankse Bank, which finally brought to light the full extent of what went wrong in Estonia.

Part One explains the background to the report, the terms of reference, and the definitions of what constituted "suspicious" both in terms of customers, accounts, transactions and people associated with the bank.

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Companies House - it's time to Act19 Nov 202300:20:39

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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Episode 5 - The Billion Dollar Deal03 Feb 201900:21:24

In this episode we look in some detail at payments made from Danske Estonia to three specific countries - Spain, UK, and Latvia. The outcome will surprise some and intrigue all.

It's a more complex episode because that's the way that Dark Money Launderers work and introduces, for the first time, direct references to the Magnitsky affair.

It also demonstrates that, if you look carefully enough, all of these payments, entities and schemes are connected.

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Episode 4 - The Billion Dollar Hold27 Jan 201900:20:30

In this episode we look at a specific set of transactions within Danske Estonia - those emanating from accounts which are also located there. We do so because, of all the transactions that the bank handled, these are the ones it ought to have known most about as it would have (or should have) held "Know Your Customer" information on them. As we will see, it didn't appear to have helped them spot highly suspicious connections between supposedly unconnected accounts.

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Episode 3 - The Billion Dollar Shuffle20 Jan 201900:28:08

If you really want to understand why this was such a noteworthy failure of financial crime controls, this is the episode you really must listen to.

We take the audience through the many different elements that constitute "suspicious activity" and then explain those elements that are observed within the bank statements from Danske.

If you’d like more information you can always visit https://grahambarrow.com/


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Episode 2 - The Launching of a Laundromat13 Jan 201900:28:18

Episode 2 brings a detailed explanation of the acquisition by Danske Bank of, amongst other things, the branch in Estonia which was the centre of the money laundering operation. It provides details and context as to the surrounding elements, all of which help to understand why it has been such a headline grabbing debacle.

If you’d like more information you can always visit https://grahambarrow.com/

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Episode 1 - The Background06 Jan 201900:17:05

This is the first in a series of podcasts which explain in a non-technical way how "Dark Money" (e.g. money laundering, corruption, bribery, tax evasion) enters the financial system and infects everything it touches.

It explains what Dark Money is, why it matters and takes an early look at some of the challenges facing the banks and other financial institutions. 

It also gives a flavour for some of the episodes still to come. 

If you’d like more detail you can always visit https://grahambarrow.com/

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A close shave – Ockam’s razor and plausibility17 Oct 202300:21:44

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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Ownership, control, or influence? UBOs and further complications15 Sep 202300:19:27

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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Ownership, control, or influence? It’s time for the UBO question!07 Sep 202300:23:39

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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A Neidle in a tax scam23 Aug 202300:16:44

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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A view from the Farage side03 Aug 202300:20:49

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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You find what you look for!05 Jul 202300:16:33

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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Hot spots and intelligence 216 Aug 202400:18:40

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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Bias and noise – how they differ and why it matters20 Jun 202300:21:10

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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MI oh MI What a Wonderful Day03 Jun 202300:20:36

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.

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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/

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