Money laundering regulation: A bridge too far?
| Published date | 01 March 1997 |
| DOI | https://doi.org/10.1108/eb024928 |
| Pages | 207-214 |
| Date | 01 March 1997 |
| Author | Sue Thornhill |
| Subject Matter | Accounting & finance |
Journal of Financial Regulation and Compliance Volume 5 Number 3
Money laundering regulation: A bridge too
far?
Sue Thornhill
Received: 22nd April, 1997
British Bankers' Association, Pinners
Hall,
105-108 Old Broad Street, London EC2N 1EX;
tel:
0171 216 8863; fax: 0171 216 8907.
Journal of Financial Regulation
and Compliance, Vol. 5, No. 3,
1997, pp. 208-214
© Henry Stewart Publications,
1353-1988
Sue Thornhill is a Consultant to the British
Bankers' Association on money laundering
prevention, and a Director of MHA Con-
sulting Ltd. She is the principal author of
the UK Money Laundering Guidance Notes
for the financial
sector,
and represents the
UK banking sector on money laundering
issues within Europe. Sue is a member of
HM Treasury's Money Laundering Experts'
Group, providing an overview of financial
sector compliance with the UK's
anti-
money laundering regime, and regularly
assists other countries and financial sec-
tors to develop their own anti-money laun-
dering strategies based on UK and
European experiences.
ABSTRACT
The 1997 revised version of the UK Money
Laundering Guidance Notes for the financial
sector
are about to be published. They represent
the results of a year's consultation and clearly
demonstrate the financial sector's commitment
not to be tainted by criminal money. However,
the fight against laundering the proceeds of
crime has long since moved away from the con-
cept of
suitcases
full of
cash
across bank coun-
ters,
and the self-regulatory process must now
encompass every part of the financial sector,
going beyond the requirements of the Regula-
tions themselves. Financial sector businesses
have committed significant
resources
to the fight
against crime, but this has not been matched by
investment in the investigation, prosecution and
confiscation process. As the financial sector
requirements become more onerous and
involved, questions are being asked whether
more than enough is being required of financial
sector
businesses.
The more contentious areas of money
laundering prevention are examined in this
paper, together with the arguments for and
against self-regulation.
INTRODUCTION
Banks and other financial sector businesses
may be excused for believing that the
whole burden of money laundering pre-
vention is falling fairly and squarely on
their shoulders with precious little to show
for their efforts. Prosecutions and confisca-
tions are abysmally low in relation to the
suspicious transaction reports that are sub-
mitted annually to the National Criminal
Intelligence Service (NCIS) (16,170 in
1996) and feedback to the financial sector
on the value of their intelligence is almost
non-existent. Notwithstanding the UK
financial sector's continued efforts, US offi-
cials continue to point the accusing finger
at the City of London claiming that it is
the washhouse of the world and that UK
banks turn a blind eye to possible money
laundering activities out of fear of being
rude to their customers. So who is right,
do the facts prove the case one way or
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