Podcasts by The Dark Money Files

NatWest Bank and HSBC: The King, his cleaner and the thirsty aspidistra from 2022-01-27T12:00

We bring this trilogy of episodes around transaction monitoring failures to an end with a final review of the NatWest case and a comparison with the recent fine levied against HSBC.

What’s...

NatWest Bank and the Bradford Laundromat - part 2 from 2022-01-10T08:00

In this episode we bring you the second part of our deep dive into the criminal prosecution of NatWest through the lens of the Statement of Facts which accompanied the guilty verdict.

This...

NatWest Bank and the Bradford Laundromat - part 1 from 2022-01-03T15:00

In this episode we bring you part one of a deep dive into the criminal prosecution of NatWest 
through the lens of the Statement of Facts which accompanied the guilty verdict.

No ma...

Green flags and white lists from 2021-12-26T12:00

In this episode we want to move away from always being suspicious and look at the other side of the coin. Can we use green flags to help identify suspicious behaviour from a very different angle...

Companies House Advanced Search from 2021-12-08T21:00

In this episode we enthusiastically review the new advanced search function recently launched on the Companies House website. We also make a heartfelt plea for other corporate registers to look ...

Regulators, statistics and benchmarking from 2021-12-04T21:00

In this episode we look at how the FCA’s REP-CRIM report can assist firms in assessing the effectiveness of their AML controls through both trend analysis and benchmarking against their peers.  ...

Set the controls for the heart of the risk from 2021-11-03T13:00

In this episode we review the need for firms to review, and adjust as necessary, their financial crime control environment. We also talk about some of the triggers which might cause these adjust...

The Pandora Papers from 2021-10-27T13:00

In this episode we give our views on the Pandora Papers and some of the broader considerations which might flow from their release.

Everything you ever wanted to know about remediation but were afraid to ask! from 2021-10-11T08:00

Remediation programmes are becoming an all too frequent feature of life for financial crime compliance departments, so we we’ve put together a summary of good practice, do’s and don’ts and other...

It's RAG week at The Dark Money Files from 2021-09-27T10:00

Sometimes you just have to go back to basics. And this week it's risk. 

Does low risk equal no risk? Is all risk equal? Should you ever do EDD on a low risk customer?

We a...

Alternative Laundries 4 - Informal Value Transfer Systems from 2021-09-07T06:00

In this episode we wander away from traditional banking intro the world of informal value transfer systems. Oh, and we look at the price of missile launchers. But you’ll need to listen to unders...

Alternative Laundries 3 - Art, auctions, sanctions and shells from 2021-08-14T12:00

Occasionally, we record an episode which is truly an exclusive, and this is one of them.

This episode started life as a straightforward explanation of the use of art and auctions in mon...

Dark Money Conference Special from 2021-08-13T13:00

This is just a very quick episode to let everyone know about the upcoming Dark Money Conference. It's online so it doesn't matter where in the world you are and it' going to be gr...

The FCA's Dear CEO AML Letter from 2021-08-06T19:00

We interrupt our series on Alternative Laundries to review the recent FCA Dear CEO AML letter which, whilst aimed squarely at UK financial institutions, will have relevance across the world, esp...

Alternative Laundries 2 - What are the odds? from 2021-07-26T09:00

In the second part of our Alternative Laundries series, and against all the odds, we turn our attention to casinos and gambling. It's a big deal!

Alternative Laundries from 2021-07-12T09:00

In this episode, we dive into the world of alternative money laundering methodologies, starting with lending and insurance.  And we find out that, with a bit of imagination, any store of value c...

Stings, Hacks and Honeypots from 2021-06-24T08:00

Following the news that the FBI and Australian Federal Police had managed to seed a bogus “encryption device” into a huge global network of organised criminal gangs, followed by an equally globa...

Financial Intelligence Units and the Egmont Group from 2021-05-24T09:00

In this episode we talk all things FIU along with the history and role of the Egmont Group. We discover the different flavours of FIU and how they work with the other elements of government and ...

Everyone's a critic! from 2021-05-04T08:00

In this episode we look at the role of critical thinking in the world of Financial Crime Compliance. What it is, how it works and some examples of critical thinking in practice. 

And we co...

We're going Dutch for this round! from 2021-04-23T08:00

With the breaking news that ABN AMRO have been fined just under €500m and three former executives are currently subject to a criminal investigation, we draw out the main themes emerging from the...

NatWest bank charges and boiling a frog from 2021-03-26T19:00

In this episode we talk about the recent criminal charges brought against NatWest Bank and liken the underlying issues to boiling a frog. Of course. 

IFF only we knew: Measuring illicit financial flows from 2021-03-03T09:00

In this week’s episode we deconstruct a  recent paper from the.United Nations Office on Drugs and Crime which defined what is meant by an illicit financial flow and which proposed a statistical ...

Formed in the USA - Beneficial Ownership and the Corporate Transparency Act from 2021-02-09T15:00

In this episode, we look at the newly enacted Corporate Transparency Act, specifically in relation to the new beneficial ownership requirements in the US, how they will work, who is affected and...

British Shells and the Beirut Blast from 2021-01-17T15:00

The massive explosion in Beirut. Sanctioned individuals. Dangerous chemicals. UK shell companies. ISIS. Russia. Syria. What connects them all? 

We do.

There is an accompanying ...

TDMF - review of the year: Part Four from 2021-01-05T14:00

In the fourth and final part of our review of the year we talk about Woolly Rhinos, Chang'e 5 and Panto Dames. Recombinant vector vaccines, Edward Snowden and Dread Pirate Roberts. Plus we ...

TDMF - review of the year: Part Three from 2020-12-30T17:00

In a highly alliterative third part of our review of the year we talk about Jumbo Jets, Mexican Mammoths, PP Tapes, Kim and Kanye, the Beirut Blast, Dangerous Drugs and Strange Stars.

J...

TDMF - review of the year: Part Two from 2020-12-24T13:00

Following rapidly on the heels of Part One, we bring you part two of our review of the year. This time we chat about news stories from April to June including Kim Jon Un, David icke, Elon Musk a...

TDMF - review of the year: Part One from 2020-12-23T16:00

In a complete departure from our normal podcast we bring you part one of an unscripted conversation between Ray and Graham, looking back at some of the major news stories of the year (noting to ...

Suspicious Activity Reports - Under the Spotlight from 2020-12-06T14:00

Following hard on the heels of the FinCEN files, the UK has just published its review of the SARs filed in 2019 which gives us the opportunity to look in detail at the headline figures and chat ...

Sanctions (Room) 101 from 2020-11-30T10:00

At long last (some may say) we look at various types of sanctions, the people or entities to whom they may be applicable, and the main issuers of sanctions lists, explaining (at a high level) ho...

Unexplained Wealth Orders - a primer from 2020-11-11T10:00

In this episode we look at Unexplained Wealth Orders (UWOs) - explaining the law, how they are obtained, who they are obtained against and some of the initial uses to which they have been put. Listen

Companies House: It's time to reform (maybe, if we can find the time and money) from 2020-10-27T13:00

In this episode we look at (and broadly welcome) the proposed reforms to Companies House - an issue which matters globally given the ubiquity of UK entities in global money laundering schemes. Listen

The Dark Money Conference - our post conference review from 2020-10-08T12:00

Following our hugely successful Dark Money Conference in association with fscom, Ray and Graham take a bit of time out to look back at the highlights and draw out some of the compelling themes t...

The FinCEN Files Special from 2020-09-28T18:00

Following the release of the #FinCENFiles and the involvement of The Dark Money Files in the story, we have recorded our longest and most in depth episode ever, looking at what it all means.

It's the Dark Money Conference call! from 2020-09-09T07:00

In advance of our online conference at the end of September, we review, the speakers, the panels. the subjects and the additional content that subscribers will receive for their very modest outl...

HMRC, TCSPs and other impossible scrabble hands from 2020-09-02T13:00

In this episode we review the recent guidance issued by the UKs tax regulator (HMRC) for the benefit of Trust and Corporate Services providers. Amongst other things, it provides a very clear and...

What's your source? Wolfsberg, Wealth and Funds from 2020-08-14T14:00

We're back for Season 5! 

We begin with a look at the new Wolfsberg guidance around Source of Wealth (SoW) and Source of Funds (SoF). Whilst we're broadly very supportive, the...

Deutsche Bank and the DFS NY: Part Three - Danske Bank from 2020-07-22T10:00

The third part of our look at the Consent Order issued by the DFS NY against Deutsche Bank throws up some worrying inconsistencies between the CO and the Bruun & Hjejle Danske bank report. W...

Deutsche Bank and the DFS NY: Part Two - FBME from 2020-07-21T17:00

In part two of our special report into the Consent Order issued by the DFS NY against Deutsche Bank we look at its troubled relationship with FBME, the Cyprus based subsidiary of the Federal Ban...

Deutsche Bank and the DFS NY: Part One - Epstein from 2020-07-18T12:00

In the first of a trilogy of special episodes relating to the recent Consent Order agreed between Deutsche Bank and the Department of Financial Services - New York, we look in detail at the natu...

A fine day in London and Stockholm (part 2) from 2020-07-10T09:00

In this second part of our review of recent fines against SEB in Sweden and Commerzbank in the UK we dive into the detail of the Commerzbank Final Notice which reveals one or two surprises!

A fine day in London and Stockholm from 2020-07-01T09:00

In this episode we begin our review of the Commerzbank fine by the FCA and give a brief overview of the SEB fine by the Swedish FSA. What can we learn from these events?

Have a listen t...

Significant Control - who is and who isn't a PSC from 2020-06-20T14:00

In this episode we review the recent report by David Leask and Richard Smith published on the from 2020-05-10T18:00

This week we look at the impact of the coronavirus on bank's financial crime controls, processes and systems. We also give an update on the Dark Money Files Conference which is still going ...

Lifting the spell of dirty money - we review the EBF report (Part 2) from 2020-04-28T13:00

Part two of a two part episode reviewing and commenting on the recommendations contained in the recent European Banking Federation's review of the role that banks need to play in the fight ...

Lifting the spell of dirty money - we review the EBF report (Part 1) from 2020-04-14T19:00

Part one of a two part episode reviewing and commenting on the recommendations contained in the recent European Banking Federation's review of the role that the banks need to play in the fi...

Coronavirus special - we're going"Live Online" from 2020-04-01T11:00

A short episode announcing the birth of "The Dark Money Files Live Online". We're just finalising the right platform, material and timings and subscriptions will open shortly.
Listen

Swedbank - the Clifford Chance report from 2020-03-23T19:00

Following the release of the Clifford Chance report into Swedbank's High Risk Non Resident portfolio (HRNR) in the Baltic States, we have recorded a special episode based on our initial rev...

Let's get together! from 2020-03-13T17:00

In this episode we return to the theme of effectiveness, stick up for Deutsche Bank, prefer the Avengers over Batman and announce our forthcoming Dark Money Conference.

Let's talk about sex(ism)! from 2020-02-21T11:00

In what is probably the most important episode we've recorded to date, we talk about the way in which money laundering is reported and the potentially sexist narrative that underpins it. Listen

Ali Moulaye rides again - the OCCRP and the Azerbaijani Laundromat from 2020-02-09T20:00

In this episode we look at the recent proposed defamation case between Javanshir Feyziyev and the OCCRP and the role that The Dark Money Files played (so far as we are able to talk about it) in ...

The Financial Crime Guide from 2020-01-25T11:00

In this special episode to launch Season 4 we look at the newly revamped FCA - Financial Crime Guide and decide that it is an invaluable tool for financial crime professionals wherever in the wo...

The Business Wide Risk Assessment from 2020-01-09T15:00

In this last episode of season 3 we turn our attention to conducting the business (or enterprise) wide risk assessment. Why and how figure prominently.

We also look at the main elements...

Assessing Customer Risk #2 - Channel, Entity, Industry and Products from 2019-12-24T10:00

In this second part of assessing customer risk, we look at the impact of delivery channel, products, entity type and industry on the overall risk rating. We talk about the changes that new techn...

Assessing Customer Risk #1 - Geography from 2019-12-14T10:00

This week, after a brief review of the latest OCCRP stories (called #29leaks) we turn our attention to the thorny issue of customer risk assessments, starting with a focus on country or jurisdic...

SEB and its Baltic operations - a special report from 2019-12-04T08:00

We take a close look at events reported by SVT (Swedish Television) in relation to SEB's non-resident banking in the Baltics.

Based on leaked material which has been shared with us...

Risky Business from 2019-11-25T17:00

In this episode we complete our look at PEPs by going into Enhanced Due Diligence in a bit more detail before turning our attention to other high risk situations. 

Listen

It's time for a PEP talk! from 2019-11-11T09:00

In this episode we talk all things PEP. We cover how to define one, what constitutes a relative or close associate, what is the difference between source of wealth and source of funds and the th...

Panorama, Money Laundering, Whistleblowers and PEPS from 2019-11-04T12:00

In this episode we look back at a recent episode of the BBC1 news programme "Panorama" featuring drug money, gold bullion, billions of dollars of money laundering, poor treatment of wh...

Swedbank shines a light but FATF prefers privacy from 2019-10-28T16:00

This week we look at two separate issues (but there are similarities). 

First up, Swedbank published its 3rd quarter results this week and included an update on their ongoing investigat...

The feeling's mutual - The Financial Action Task Force and the Mutual Evaluation Report from 2019-10-13T15:00

This week, in honour of the first 2019 Plenary meeting of the FATF we look at the birth of the organisation in Paris in 1989 and a pillar of its existence - The Mutual Evaluation Report.

The highs and lows of correspondent banking from 2019-10-07T17:00

In this episode we look at the recent raid on Deutsche Bank in connection with the Danske Bank story, the role of correspondent banking in the story and the risks associated with it.

The world of the MLRO from 2019-09-30T08:00

In this episode we take a long hard look at the reporting requirements and all the other responsibilities placed on the Money Laundering Reporting Officer.

We look at an example of what...

Looking back and looking forward from 2019-09-24T14:00

In this episode we reflect on some past episodes, chat about the recent Dark Money Files Live event and announce some exciting news for followers of the podcast.

New ways to bring you D...

The EU Money Laundering Report from 2019-09-09T10:00

In this first episode of season three we give our listeners an overview of the report to the EU Parliament and Commission looking at recent money laundering cases in Europe and what we can learn...

The Deutsche Bank Story, Part Four: The road to ruing from 2019-08-11T19:00

In this final episode of the Deutsche Bank story we look at the acquisition of Morgan Grenfell and Bankers Trust along with the banks somewhat strange relationship with Donald Trump. We also men...

The Deutsche Bank Story, Part Three: What the FCA found from 2019-08-06T15:00

In this episode we complete our review of Deutsche Bank's inspection by the FCA which led to them being fined £163m (and $425m by the Department of Financial Services - New York). W explain...

The Deutsche Bank Story, Part Two - The FCA comes to visit from 2019-07-28T16:00

In this second part of our in-depth review of the recent travails at Deutsche Bank we talk about the background to the Systematic AML Programme (SAMLP) visit by the FCA, the  LIBOR fine which pr...

The Deutsche Bank Story: Part One - The Mirror Trades from 2019-07-21T13:00

Given its refusal to stay out of the news, we thought it was about time to turn our attention to Deutsche Bank. In an extended set of episodes we are going to examine in detail exactly what, in ...

Extraordinary Danske developments and the need to report suspicions from 2019-06-30T11:00

We report on our involvement in recent leaks relating to Danske Bank and the potential criminal charges that can follow a failure to report. 

External reports commissioned and cancelled...

Old banks and new technologies - oil and water? from 2019-06-23T19:00

In this episode we start a conversation about FinTech and RegTech (along with a few digressions and diversions along the way). In an abbreviation heavy episode, we talk about face and voice vali...

Oh what tangled webs we weave! from 2019-06-16T12:00

Following on from our last episode looking at Bitcoin and the Blockchain, this week we look at the surface web, deep web and the dark web, explain what these different terms mean and then delve ...

Bitcoin, Blockchain and Cryptography - Time to look forward from 2019-06-02T14:00

This week, with some trepidation, we embark on an overview of some of the more esoteric elements of financial crime risk management. We attempt to explain the blockchain, cryptocurrencies like B...

Deutsche Bank's"Glitch"and Lithuania's"Pitch"- a week in AML from 2019-05-27T18:00

In this week's episode we talk about the glitch that was discovered in Deutsche Bank's transaction monitoring system (and a couple of other Deutsche Bank related news stories) as well ...

Laundromats and Legal Entities - part three: Scottish Limited Partnerships from 2019-05-19T18:00

The one you've all been waiting for! A detailed explanation of SLPs, their history, construction and how they are used to launder money - plus a further explanation of a Scottish Limited Pa...

The good, the bad and the companies - The Global Witness Report from 2019-05-12T15:00

In this special episode we review and comment on the recent Global Witness update to its reports from last year on the effectiveness of the Companies House PSC regime.

For more see: Listen

Laundromats and Legal Entities - part two: Limited Liability Partnerships (LLPs) from 2019-05-06T10:00

In an extended episode, we delve into the intricacies of UK LLPs and, using real examples, explain how the rules allow them to be constructed in a such a way as to hide ultimate ownership behind...

Laundromats and Legal Entities - part one: Limited Companies from 2019-04-28T15:00

We begin our analysis of how legal entities, in locations which have transparent corporate registers can still be used to mask ultimate ownership and control while still providing a veneer of re...

Ali Moulaye: The man, the myth and the method from 2019-04-22T16:00

In this first episode of season 2 we discuss Ali Moulaye, the man whose signature is at the base of Companies House account filings for a multiplicity of LLPs identified as being involved in a w...

Episode 10 - The Whistleblower, the UK and the Russian connections from 2019-04-07T00:00

In a sensational final look at the Danske Bank affair, we analyse the whistleblower report and definitively link it to a UK LLP (along with a few others) a small Russian Bank with Igor Putin (co...

Episode 9 - Danske Bank: The bond loop and the intermediaries from 2019-03-31T00:00

In 2013 Danske Bank executives started to examine,rather more critically, the lucrative bond sale business in Estonia. We look at the reporting and decision making process at the start of that j...

Special Episode 3 - The Swedbank/Forensic Risk Alliance Report Phase 1 from 2019-03-22T00:00

Following the release of Phase 1 of the Forensic Risk Alliance report prepared for Swedbank, we take a detailed look at that it has uncovered and where we'd like Phase 2 to go.

Episode 8 - The Missed Opportunities from 2019-03-17T00:00

We begin to look at all the different occasions, highlighted in the Bruune and Hjejle report, where the management of Danske Bank could (and arguably should) have become aware that they had a si...

Special Episode 2 - The Troika Laundromat from 2019-03-10T00:00

The second of our special episodes looking this time at the OCCRPs newly released data dubbed "The Troika Laundromat". 

Rather than spend 20 minutes criticising everyone invol...

Episode 7 - The Suspicious Activity Report (Part 2) from 2019-03-03T00:00

In this jaw-dropping episode we look under the bonnet at the situation in Estonia just after Danske had bought Sampo.

It highlights conflicting stories between what the Estonian regulat...

Special Episode 1 - The Ousting of Danske and the Arrival of Swedbank from 2019-02-23T00:00

Following an extraordinary week of developments which saw the removal of Danske from Estonia, its voluntary departure from Latvia, Lithuania and Russia, the launching of an investigation of both...

Episode 6 - The Suspicious Activity Report (Part 1) from 2019-02-18T00:00

In this episode we begin to look at the report, commissioned by Dankse Bank, which finally brought to light the full extent of what went wrong in Estonia.

Part One explains the backgrou...

Episode 5 - The Billion Dollar Deal from 2019-02-03T00:00

In this episode we look in some detail at payments made from Danske Estonia to three specific countries - Spain, UK, and Latvia. The outcome will surprise some and intrigue all.

It&apos...

Episode 4 - The Billion Dollar Hold from 2019-01-27T00:00

In this episode we look at a specific set of transactions within Danske Estonia - those emanating from accounts which are also located there. We do so because, of all the transactions that the b...

Episode 3 - The Billion Dollar Shuffle from 2019-01-20T00:00

If you really want to understand why this was such a noteworthy failure of financial crime controls, this is the episode you really must listen to.

We take the audience through the many...

Episode 2 - The Launching of a Laundromat from 2019-01-13T00:00

Episode 2 brings a detailed explanation of the acquisition by Danske Bank of, amongst other things, the branch in Estonia which was the centre of the money laundering operation. It provides deta...

Episode 1 - The Background from 2019-01-06T18:00

This is the first in a series of podcasts which explain in a non-technical way how "Dark Money" (e.g. money laundering, corruption, bribery, tax evasion) enters the financial system an...

Episode 1 - The Background from 2019-01-06T18:00

This is the first in a series of podcasts which explain in a non-technical way how "Dark Money" (e.g. money laundering, corruption, bribery, tax evasion) enters the financial system an...

Episode 1 - The Background from 2019-01-06T18:00

This is the first in a series of podcasts which explain in a non-technical way how "Dark Money" (e.g. money laundering, corruption, bribery, tax evasion) enters the financial system an...