It may be the poisoning of the Skripals (coming on top of the Litvinenko case and other suspicious deaths), or it may be the dramatisation of McMafia on the TV, but there has been a definite hardening of attitudes towards the risk of money laundering in Westminster. Parliament has pushed through laws requiring overseas territories to provide transparency on beneficial ownership. There seems to be a sense in political circles that the UK may have been overrun by commercial activities linked to Russia, perceived as a state which wants to do us harm. See Moscow’s Gold: Russian Corruption in the UK. A link can be found on www.legalrisk.co.uk/news.
There is a risk that law firms handling transactions connected with Russian money may be targeted by the non-financial Press. And there is a risk that professional services firms may be picked on as easy targets “pour encourager les autres” if their AML systems are shown to be weak. Legislation continues to come through. The Sanctions and Anti-Money Laundering Act 2018 has recently received Royal Assent. A link can be found on www.legalrisk.co.uk/news.
Almost a year on from the introduction of the Money Laundering Regulations 2017, firms need to be sure that they have brought themselves up to date, with a written Risk Assessment, compliant policies, controls and procedures, and training. The first annual review may already be falling due. We have advised leading firms on their risk assessments and independent audit of their systems.
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