A brave new world: The impact of domestic and international regulation on money laundering prevention in the UK
| Date | 01 June 2003 |
| Pages | 138-145 |
| Published date | 01 June 2003 |
| DOI | https://doi.org/10.1108/13581980310810453 |
| Author | Antony Whitehouse |
| Subject Matter | Accounting & Finance,Financial risk/company failure,Financial compliance/regulation |
A brave new world: The impact of domestic
and international regulation on money
laundering prevention in the UK
Antony Whitehouse
Received: 31st January, 2003
Head of UK Money Laundering Prevention Dept, WestLB, London Woolgate Exchange,
25 Basinghall Street, London EC2R 6AE, UK; tel: +44 (0)20 7020 2261; fax: +44 (0)20 7020 2260;
e-mail: antony_whitehouse@ westlb.co.uk
Antony Whitehouse has created the UK
Money Laundering Prevention Department
at WestLB, one of the largest German
banks specialising in the wholesale mar-
kets. He is also the Money Laundering
Reporting Officer for all the London-based
legal entities. Prior to taking up this chal-
lenging role he was the Compliance Direc-
tor for WestLB in London and has worked
at both the FSA and one of its predeces-
sors, the SFA. He was also an arbitrator
on the SFA Arbitration panel.
ABSTRACT
KEYWORDS: money laundering, legisla-
tion, proceeds of crime, MLAC, JMLSG,
FSA
This paper forms part of a presentation on the
same subject given by the author to the Regula-
tion and Compliance conference organised by
the Securities Institute in London in November,
2002. It considers the impact that domestic and
international regulation has had on money
laundering prevention in the UK from the
viewpoint of a Money Laundering Reporting
Officer dealing with the day-to-day implications
of the changes that have been brought about. It
also examines the ongoing role of the regulators
in influencing the financial services industry’s
work in the area of money laundering preven-
tion and assesses the possible impact of likely
future regulation and regulatory initiatives.
A WORLD BEFORE CHANGE
The one constant in the world of money
laundering prevention over the past few
years seems to have been change. So much
seems to have happened so quickly that it
is often necessary to sit back and take stock
of the situation to fully appreciate how
much the changes in regulation and legisla-
tion have affected the financial services
industry. To assess how far the industry has
come, all one needs to do is look back at
the state of affairs a few years ago.
This author believes that prior to 2000 it
would have been a gross understatement to
say that money laundering prevention was
not a major regulatory concern for many
in the UK, including the financial services
regulators. The author says this with some
conviction having worked both in the
compliance industry and as a regulator.
Following implementation of the first
EU Directive on Money Laundering,
1
the
Money Laundering Regulations 1993
2
(the
Regulations) have been in force in the UK
since April, 1994. It is these that set out the
requirements for customer, or client, iden-
tification. Some firms, particularly banks,
had purchased copies of the industry
Page 138
Journal of Financial Regulation
and Compliance, Vol. 11, No. 2,
2003, pp. 138–145
#Henry Stewart Publications,
1358–1988
Journal of Financial Regulation and Compliance Volume 11 Number 2
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