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Gemma Verified Group

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Ricardo Garrett
Ricardo Garrett

Anti-money Laundering Muller



"The issue with money laundering is it tends to take two to money launder: You have the criminal who committed the original crime, but then you also have the bank, the lawyer, the accountant that actually moved the money into the financial system."




anti-money laundering muller



Over the past 50 years, the U.S. has made policy changes toward curbing money laundering. Notably, Congress passed the Bank Secrecy Act in 1970, which requires banks to report cash transactions over $10,000.


Rodgers of the Center for the Advancement of Public Integrity says it may not be Trump who should necessarily worry about money laundering charges at this point. The president may have good reason to fear, according to some reports, but the person in the most pressing legal jeopardy could be Trump's former campaign manager, Paul Manafort.


"I personally think they're looking at money laundering for Manafort," Rodgers said. "It looks like they may get something there, given the sheer number of accounts he has, and the number of transactions involved."


"Anyone facing serious charges for money laundering and tax offenses involving undisclosed foreign bank accounts would have huge incentives to trade cooperation for prison time," Jonathan Winer, the State Department's top money laundering expert during the Clinton administration, told McClatchy.


This paper reports on our research towards an economic analysis of money laundering schemes utiliz-ing cryptocurrencies, which are convertible decentralized virtual currencies based on cryptographic operations. They gain ground as means to offer enterprises and its customers new payment methods, investing opportunities and some are even intended as substitutes for centrally controlled government-issued fiat currencies. Our starting point is the observation that their increasing popularity attracts the attention of practitioners and scholars, particularly because of raising anti-money laundering concerns. Consequently, work has already been conducted in this area, mainly focusing on implica-tions on anti-money laundering efforts. However, we argue that the potential benefits for criminal in-dividuals are an important, yet neglected factor in the dissemination of cryptocurrencies as money laundering instrument. Addressing this issue, the paper firstly presents the structure of the money laundering process and introduces prevailing anti money-laundering controls. This forms the basis for the subsequent analysis of contextual and transactional factors with respect to their influence on the incentives of criminals to utilize cryptocurrencies for money laundering. This aims at providing an answer to the open question, whether cryptocurrencies constitute a driver for money laundering.


The first handbook of its kind, Anti-Money Laundering: International Law and Practice published by John Wiley & Sons is now available. This 834-pages hardcover book covers key topics in money laundering and practice and makes it easy for the reader to compare the legislation and rules in different countries. This is a useful reference and guide to those seeking information on anti-money laundering, which is an important but increasingly complex subject involving a globally interconnected system of law and regulation. It will be valuable to those involved in international financial services with its in-depth coverage of anti-money laundering in some 41 countries and territories, with contributions from top-tier international specialists. This book is a concerted effort by a team of experts.


To get a better insight into the law aiming to prevent money laundering and resulting obligations, Frank Müller and his guests Christian Tsambikakis (Managing Director) and Florian Peters (Senior Compliance Manager) from Kerberos Compliance got to the heart of all the need-to-knows about the AMLA in PayTechTalk episode #65.


Through the so-called all crimes approach, the German legislator has recently enormously expanded the offence of money laundering under Section 261 of the German Criminal Code (StGB) (see also article all crimes approach), whereby all offences, whether felonies or misdemeanours, are now considered predicate offences to money laundering. Regulators are increasingly following suit, thus placing more and more obligations on those obliged under the AML.


This episode clarifies the essential questions around the AML: What is money laundering, what is the purpose of money laundering prevention, who is obliged to do so and if so, what obligations are we talking about? Furthermore, we will discuss what has to be considered in the special case of PePs (politically exposed persons) according to the Money Laundering Act and what has to be done in a suspicious case.


Florian Peters is a lawyer and Senior Compliance Manager at KERBEROS Compliance-Managementsysteme GmbH since 2020. Prior to that, Mr Peters worked at two large law firms in the field of antitrust law for several years, where he advised clients on all antitrust law issues, including compliance topics. He completed his education at the Rheinische Friedrich-Wilhelms University in Bonn, the Higher Regional Court in Cologne (Oberlandesgericht Köln) and the University of Birmingham (LL.M.). Florian Peters holds seminars on various areas of money laundering prevention with a focus on obligated persons in the financial sector.


As Susanne already covered in her latest blogpost about Payment Initiation Services, Account Information Services and the AML regulations, there will be two new payment services under PSD2: Payment Initiation Services (PIS) and Account Information Services (AIS). But does it really make sense that they are subject to the relevant anti-money laundering (AML) laws? How is this question being dealt with in the transposition laws across different EU member states?


The company is obliged to obtain, preserve, maintain and notify the registrar without undue delay of the information to be recorded in the register (s. 20(1) GwG). Companies must merely obtain, preserve and provide the relevant information to the registrar to the extent that such information has to be entered in the transparency register. Failure to comply with the duty to obtain the information is subject to draconian fines. On the one hand, a duty to investigate the facts should be avoided.6 On the other hand, however, companies are required to take appropriate internal organisational measures and, for example, put in place effective monitoring and reporting systems, in order to ensure that the information notified to the transparency register is complete and accurate.7Inspection rights of public authorities and third parties; naming and shamingAs of 27 December 2017, in particular supervisory and law enforcement authorities will be authorised to inspect the transparency register. Third parties will also be permitted to inspect the register if they can demonstrate a legitimate interest (s. 23(1) and s. 59(3) GwG). According to the explanatory memorandum, specialised journalists and non-governmental organisations will in particular be able to claim a legitimate interest if their work relates to combatting money laundering, corruption or terrorism financing.8 Third parties with a right of inspection will not, however, have access to information about the exact place of residence or the date of birth of the beneficial owner (s. 23(1) second sentence GwG).


OCT. 30, 2017: Manafort and his longtime business associate Rick Gates surrender to federal authorities in Washington, D.C., after a grand jury approved charges unrelated to the Trump campaign brought by Mueller on the previous Friday, including conspiracy against the United States, money laundering and working as unregistered foreign agents for Ukrainian clients. Both Manafort and Gates plead not guilty to those charges.


MARCH 8, 2018: Manafort pleads not guilty to charges of tax evasion and money laundering among others. Gates, who was indicted alongside Manafort, pleaded guilty in February to two felony counts of conspiracy against the U.S. and lying to federal authorities, and as part of a plea deal, had begun cooperating with the special counsel and began sharing incriminating information about Manafort.


Policymakers, regulators and investigative journalists will also benefit from the comprehensive introduction to virtual assets and blockchain analysis, due diligence and risk management, including the implications of EU anti-money laundering directives (AMLDs) and ultimate beneficial ownership (UBO) requirements.


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