A report says she is. And that London and Virgin Islands firms didn’t do enough to stop her

Gulnara Karimova has already achieved a measure of fame – or notoriety. She is the daughter of Islam Karimov, who was president of Uzbekistan from 1989 until 2016, when he died. There was a period when it was thought that she would succeed him. She also appeared in pop videos under the stage name, “Googoosha,” she ran a jewellery company and she served as ambassador to Spain.

And now, an NGO, Freedom For Eurasia, released a report detailing how Karimova built a £200m empire on properties from London to Hong Kong with funds obtained through bribery and corruption.

Continue reading
aml ongoing monitoring banner

Ongoing monitoring is an essential part of an effective anti-money laundering programme. Regulations are constantly changing, clients’ circumstances are evolving and the ramifications of making a mistake are getting increasingly high. Ongoing monitoring is required to determine whether a customer continues to match the risk profile assigned to them at onboarding.

It’s essential to stay on top of compliance requirements to avoid exposure to financial crime and penalties. We have created a comprehensive guide to ongoing monitoring, including some tips for law firms.

Download the guide

Continue reading

What your firm needs to know about transactions from China

The Legal Sector Affinity Group (LSAG) recently published an advisory notice on the risks involved in Chinese transactions that do not use the normal banking system or have not complied with Chinese currency controls.

Bottom line: A customer misleading the Chinese authorities about the reasons for a currency transfer is not a crime in the UK. But… it is something to consider. 

Continue reading

London-based Discreet Law took on Wagner group head Yevgeny Prigozhin as a client

Yevgeny Prigozhin, founder of the Wagner mercenary group, a Russian paramilitary organisation, was able to pass UK anti-money laundering (AML) checks by submitting a utility bill in the name of his 81-year-old mother. The sanctions-hit Russian warlord has been accused of human rights abuses around the world.

Continue reading

Updates from the FATF plenary and new sanctions on Russia

Two of Africa’s largest economies and a G20 member, Nigeria and South Africa, have been added to the FATF’s grey list of countries with deficiencies in their anti-money laundering procedures. At the same plenary on 24 February 2023 in Paris, Morocco and Cambodia were both removed from the FATF’s grey list.

These changes are likely to be adopted formally by the UK and EU in further legislation, however it is worth considering these countries high risk from now given the FATF’s concerns. 

Continue reading

What are the implications for firms that fall short?

You conducted your customer due diligence (CDD) when you onboarded your client. It’s all part of your effort to stay compliant with Know Your Customer (KYC) and Anti Money Laundering (AML) regulations.

But the regulations are constantly changing, your client’s circumstances are evolving and the implications for making a mistake are getting increasingly high. You need to keep track of the changing risks. You need to stay on top of compliance requirements to avoid exposure to financial crime and penalties.

It is no longer sufficient to do your due diligence at onboarding and in periodic intervals. 

Firms need to perform ongoing monitoring for AML to capture any developments, update customer profiles and keep track of the changing risks.

Continue reading

The AML crackdown continues, this time targeting one of Britain’s biggest banks

The UK’s Financial Conduct Authority (FCA) has launched an investigation into Barclays for suspected ongoing failings in compliance and anti-money laundering (AML) systems.

The Financial Times reported that the FCA issued a notice last spring requiring an independent review of the bank’s financial crime detection and prevention systems. The review was triggered by concerns over the amount of know-your-customer (KYC) and AML cases at Barclays.

Continue reading

The new offences of failure to prevent fraud are likely to shake up corporate compliance for all UK business. How will they work in practice?

The UK government have announced they are pushing ahead with a game-changing new regulation to expand the ‘failure to prevent’ family of offences to failure to prevent fraud. 

Proposed amendments could even see corporate officers jailed if they take a decision, or fail to take a decision, that could lead to economic crime such as fraud, false accounting or money laundering being committed.

Failure to prevent encompasses a wide array of compliance failures, from not having the right policies in place, to a lack of procedures to even training courses that aren’t effective in delivering the right information to employees. 

Continue reading

Download our detailed guide: “Failure to Prevent: A Guide to Compliance” and find out more about the family of failure to prevent offences, including the new failure to prevent fraud offence currently going through the UK parliament.

Failure to prevent fraud will apply to all businesses, and require them to have certain procedures in place, or face criminal liability.

This free guide includes:

  • What is failure to prevent?
  • What’s new in failure to prevent?
  • Why is failure to prevent fraud being considered and who will it cover?
  • Failure to prevent fraud in detail
  • Failure to prevent tax evasion
  • Failure to prevent bribery
  • The future of failure to prevent

Download your guide to failure to prevent now and stay on top of this game-changing new regulation that’s set to shake up corporate compliance.

Download the guide

The ‘failure to prevent’ concept is being expanded to fraud, false accounting and money laundering

The UK government have announced they are pushing ahead with a game-changing new regulation to expand the ‘failure to prevent’ family of offences to failure to prevent fraud. 

The announcement came during Parliamentary debate over the Economic Crime and Corporate Transparency Bill which aims for a wide-reaching attempt to tackle all aspects of economic crime, along with reform of Companies House.

Continue reading