In September 2019, HM Revenue and Customs (HMRC) published its list of businesses that have not complied with the Money Laundering Regulations 2017 (MLR 2017) for the tax year 2019 to 2020. Within this, it revealed that it has fined Touma Foreign Exchange Ltd £7.8 million for a wide range of serious failures under the Money Laundering Regulations.
Tucked in between the “reasonable worst-case” scenarios for food, trade and fuel is a stark one liner: “Law enforcement and information sharing between U.K. and EU will be disrupted”. The reduction in capability of law enforcement agencies that will come from a no deal will, according to government documents, be accompanied by an increase in cross-border crime.
The Serious Fraud Office (SFO) was established to investigate and prosecute cases involving serious or complex fraud, a mission that inevitably leads it to the corporate sector. In 2010, it was given two significant tools in dealing with companies: a simple route to corporate criminal liability for bribery cases in the Bribery Act 2010 (the stick); and a means of incentivising a company fixed with corporate criminal liability to co-operate with the SFO by entering into a deferred prosecution agreement (DPA) and so avoiding a conviction (the carrot).
The National Crime Agency announced last week that it has secured three Unexplained Wealth Orders as part of its investigation into London property linked to “a politically exposed person believed to be involved in serious crime.” We are told that the UWOs are for three residential properties in prime locations – originally bought for more than £80m and held by offshore companies.