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). Send us a text Support the show Follow us on Li…

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. Send us a text 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 se…

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. Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitte…

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. Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-l…

"...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). Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at http…

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. Send us a text 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…

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! Send us a text 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 …

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. :) Send us a text 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 websit…

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

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 Send us a text Support the show Foll…

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. Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitte…

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/ Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-…

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/…

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. Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at https://twitt…

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. Send us a text 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_file…

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. Send us a text 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.th…

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. Send us a text 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 …

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. Send us a text 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 …

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). Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-mo…

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

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! Send us a text 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_…

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

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. Send us a text Support the show Follow us on LinkedIn at http…

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. Send us a t…

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! Send us a text 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.t…

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. Send us a text 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/…

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. Send us a text 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 se…

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. Send us a text 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://ww…

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 KUR…

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 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. Send us a text 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.…

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

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? Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-…

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. Send us a text 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://…

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. Send us a text Support the show Follow us on LinkedIn at https://www.link…

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. Send us a text 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 web…

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. Send us a text 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…

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). Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at …

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…

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. Send us a text 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 …

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

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 …

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

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

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 liv…

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. Send us a text 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 o…

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! Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.com/company/the-dark-money…

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! Send us a text Support the show Follow us on LinkedIn at htt…

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. Send us a text Support the show Follow us on LinkedIn at https://www.linkedin.co…

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. Send us a text Support the show Follow us on L…