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TitreDateDurée
Transparency and trust issues: the secret life of property29 mai 202500:18:33

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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Trigger warning!14 avr. 202500:17:24

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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The sharing of suspicion16 mars 202500:17:41

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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Don't let mules make an ass of your firm08 févr. 202500:19:38

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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We're scamming, we hope you like scamming too...15 déc. 202400:15:23

"...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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Unheard voices - fine outcomes26 nov. 202400:18:56

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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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 sept. 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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Hot spots and intelligence 216 août 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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Hot spots and intelligence03 juil. 202400:18:06

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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Are corporate entities the Swiss army knife of financial crime?04 juin 202400:17:10

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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Organised Crime - two's company but three's an OCG 25 mai 202400:20:14

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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A proliferation explanation conversation07 mai 202400:18:28

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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It’s payback time! – the new UK regime for mandatory scam reimbursement26 avr. 202400:22:26

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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The democratisation of crime22 mars 202400:15:53

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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Bar Wars - Attack of the Clones11 févr. 202400:20:38

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 EU07 févr. 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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Are PEPs domestic?15 janv. 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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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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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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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 sept. 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 sept. 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 août 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 août 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 juil. 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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Bias and noise – how they differ and why it matters20 juin 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 juin 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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Show me the money!01 mai 202300:20:11

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.

More information on KURE (brought to you by our sponsors Deep PoolmLtd) can be found at www.deep-pool.com. 

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VATs the problem?13 avr. 202300:15:43

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 him being sent £500,000 in debt enforcement letters.

And, in a first for The Dark Money Files, this podcast is now sponsored which will secure the ongoing future of the podcast and ensure we can continue to deliver a quality product.

Here’s a link to our sponsor’s website: https://www.deep-pool.com/

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Investing in testing 2 - Is it in the test?27 mars 202300:21:47

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. 

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Investing in Testing - why assessment matters: Part 109 mars 202300:21:50

Does your assessment programme correlate to individual performance? 

And if not, why not?

Part one of a journey on the road to cognition.

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KYC - The Canary in the Coal Mine20 févr. 202300:24:06

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?

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Dr Blake’s casebook – a roundup of stories you may have missed25 janv. 202300:20:04

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.

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Can we have the Bill please?16 janv. 202300:18:33

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.

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Trivia - when three paths meet03 déc. 202200:21:03

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. 

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AOB – recent publications and guidance21 nov. 202200:18:50

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.

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Fraud part three: Watcha gonna do about it!17 oct. 202200:16:16

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).

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Your company is not welcome here!22 août 202200:15:49

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, to this recent episode of BBCs You and Yours:

https://www.bbc.co.uk/programmes/m0019z2g

 

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Fraud part two: The grift that keeps on grifting25 juil. 202200:20:46

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.

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Fraud, intents and purposes25 juin 202200:15:36

In this pun laden episode, we start to delve into the world of fraud. More to follow…

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Synthetic data and real-world applications: The FCA call for input29 mai 202200:17:09

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 why contributing to this call is so important.

Link to the call: https://www.fca.org.uk/publication/call-for-input/synthetic-data-to-support-financial-services-innovation.pdf 

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Tax: Avoidance, evasion, and small umbrellas27 mai 202200:23:19

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.

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Selfies, Swipes and Security - authentication in the digital age05 mai 202200:21:25

In this episode we look at all things digital and how it is changing the landscape of authentication whilst making KYC more dynamic.

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A view from the dark side – Part 315 mars 202200:21:14

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 at $15/kg make for a lively episode! 

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A view from the dark side - Part 203 mars 202200:15:49

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.

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A view from the dark side - Part 115 févr. 202200:19:06

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!

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NatWest Bank and HSBC: The King, his cleaner and the thirsty aspidistra27 janv. 202200:27:29

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!

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NatWest Bank and the Bradford Laundromat - part 210 janv. 202200:26:53

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.

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NatWest Bank and the Bradford Laundromat - part 103 janv. 202200:27:29

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.

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