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  • BDO's AML Watch - September 7th, 2023

BDO's AML Watch

07 September 2023

Richard Carty, Director, RAS |

Caribbean AML/FCP

Cuba Uncovers Human Trafficking of Cubans to Fight for Russia in Ukraine

  • Cuba has exposed a human trafficking ring that forced its citizens to participate in the conflict in Ukraine on behalf of Russia. The Cuban Foreign Ministry announced that efforts are underway to "neutralize and dismantle" this network. In late May, a Russian newspaper in Ryazan city disclosed that a number of Cuban citizens had entered into agreements with Russia's armed forces and were subsequently sent to Ukraine in exchange for Russian citizenship. Cuba has confirmed that it is actively pursuing legal action against those responsible for coercing its citizens into combat in Ukraine.

Caribbean Financial Crimes Watchdog Determining Guyana’s Compliance with Global Standards

  • The Caribbean Financial Action Task Force (CFTAF) initiated a nine-day assessment of Guyana's preparedness to combat money laundering, terrorism financing, and the proliferation of nuclear, chemical, or biological weapons. Following this on-site evaluation, a Mutual Evaluation Report on Guyana will be generated and presented at the CFATF Plenary in March 2024. Attorney General and Minister of Legal Affairs, Anil Nandlall, highlighted Guyana's two recent legislative achievements, including the passage of a comprehensive AML/CFT Bill, regulations, a Real Estate Agents and Brokerage Bill, and a National Compliance Commission Bill. Additionally, the government has executed a memorandum of understanding among various stakeholder entities to bolster administrative efforts.


Global AML/FCP

Three British Based Criminals Sentenced in US Over Inheritance Scam

  • Three individuals who targeted elderly and vulnerable victims in a multi-million dollar inheritance fraud scheme have received prison sentences totaling over 21 years, following their guilty pleas in the United States. Meanwhile, Spanish authorities apprehended additional suspects connected to the fraud in Madrid, with coordinated enforcement actions occurring in Portugal. In response to revelations about an expansive global network of fraudsters collaborating to pilfer millions, the National Crime Agency worked in close partnership with the US Department of Justice, US Postal Inspection Service, and European counterparts. Together, they orchestrated international operations to locate and detain suspects and gather crucial evidence.

Addressing Economic Crime Must "be at the heart of modern policing", says Lord Mayor

  • Speaking at the 40th International Symposium on Economic Crime in Cambridge, Nicholas Lyons stated, fraud, which accounts for 41 per cent of all crime in England and Wales, "increasingly recognised as a national security threat, especially at a time when technological developments such as advances in artificial intelligence present so many more opportunities for deception and disruption." The Insurance Fraud Enforcement Department (IFED) of the City of London Police has taken significant action, apprehending and interrogating over 2,700 suspects. Their efforts have led to more than 1,000 convictions and cautions, resulting in the recovery of assets valued at nearly £3 million for crime victims. Additionally, in collaboration with the City of London Police, the City Corporation is fortifying the broader response to economic crime within the criminal justice sector. This includes a substantial £350 million investment in a new court complex in the city, designed with specialized facilities to handle economic and cybercrime cases.
US, Partners Say they have Disrupted 'Qakbot' Network
  • US authorities have announced the successful takedown of the infamous "Qakbot" malware platform, widely utilized by cybercriminals for various financial offenses, through an international law enforcement effort. Qakbot, initially identified over a decade ago, typically propagates through malicious emails designed to deceive recipients. Termed "Duck Hunt," this operation was a collaborative endeavor involving the Federal Bureau of Investigation (FBI), as well as the participation of France, Germany, the Netherlands, the United Kingdom, Romania, and Latvia. During the period spanning from October 2021 to April 2023, investigators uncovered that Qakbot administrators collected an estimated $US58 million in ransoms paid by victims. FBI Director Christopher Wray noted that the victims ranged from financial institutions along the US east coast to a vital infrastructure government contractor in the Midwest, to a medical device manufacturer on the west coast in a statement.


Industry Updates

Navigating the AML Compliance Journey: When is it Time to Hire an AML Officer?

  • In today's financial landscape, characterized by increasing operational intricacies and an ever-shifting regulatory environment, the significance of AML compliance within businesses has never been more pronounced. This holds especially true for FinTech companies, where the decision of when to onboard an AML Officer can significantly impact the organization's journey. Identifying the right moment to hire an AML Officer can be likened to precisely threading a needle in the vast tapestry of global finance. This pivotal decision extends its influence beyond mere regulatory adherence and financial stability; it casts a profound shadow on an organization's market reputation, internal culture, and growth trajectory. The timing of appointing an AML Officer should be viewed as a strategic choice, taking into account obligations on the regulatory front, the complexities inherent in operations, aspirations for growth, the management of reputation, and the need for capacity enhancement. This appointment stands as a testament to an organization's unwavering commitment to combatting financial crime and upholding ethical business practices.