Global Threat Assessment
by John Cusack
Despite the limitations presented in estimating criminal activity designed to be hidden, the results in the Global Threat Assessment present a bleak picture.
Criminal markets are generating more illicit funds than at any other time in our history, with ever more harmful effects inflicted against every Country, against billions of people and against our increasingly fragile environment.
We are witnessing the transformation of organised crime into very big business, leveraging networks to connect criminal actors, adopting poly criminality, embracing new cyber tools and opportunities afforded by the transformation to digital.
How big, which Countries, by what Methods and by which Gangs, is summarised in this Global Threat Assessment, using over 100 publicly available studies or reports from credible sources, together with personal observations and recommendations from the author.
In this Interview with the Hong Kong Monetary Authority’s Stewart McGlynn, who leads the Regulators Anti Money Laundering Team, Financial Crime News wanted to know more about HK, the risks and threats, de risking, the recent FATF Report, follow up actions, Regtech, PPP and much more besides. The interview reveals that HK has achieved a lot but also has plans to do more, much of which is exciting and offers the prospects for increased efficiency and effectiveness in fighting financial crime.
FCN: HK is one of the largest and most respected international financial and trading centres, but what attributes do you think are necessary to build and maintain this reputation?
SM: There are several key attributes which overlap to some degree and which can be related directly to anti-money laundering work.
How did Jacob Zuma, a hero of the Apartheid struggle, a prison mate of Nelson Mandela, and the 4th President of post apartheid South Africa come to be described in this book as the “Enemy of the People.” Chapter by chapter,
Zuma is revealed, by authors; Adriaan Besson and Pieter du Tot, first when his financial adviser was convicted of soliciting bribes for his boss, to how he renovated his personal homestead from extensive state-funds that he has still not repaid, despite an order by South Africa’s highest court that he must do so, to how his friendships, particularly with the controversial Gupta family, finally brought him down.
In 2018, after 9 years as President of South Africa, Jacob Zuma was removed from office by his own party, the ANC, for supporting a form of state capture which enabled so called friends to influence government appointments and contracts, costing billions of Rand.
Last week at the 18th triennial meeting of CITES members, those responsible for regulating the international wildlife trade closed the conference which mostly saw victories for animal welfare. In a previous recent Financial Crime News Post we correctly predicted Giraffes would make it onto Appendix 2 for the first time, that proposals to weaken trade restrictions on Rhino horn would be defeated and African Elephant proposals to increase trade would also be rejected. More good news came with the decision to include Mako Sharks, Giant Guitarfish and Wedgefish on Appendix 2 which will provide much needed protection.
Another decision to be lauded limits the export of wild African elephants, so that elephants from Botswana, Zimbabwe, Namibia, and South Africa can only be exported to African countries where elephants live or used to live.
On 13 June 2019, the US Department of Justice, U.S. Attorney’s Office, Southern District of New York indicted four individuals, Moazu KROMAH, Amara CHERIF, Mansur Mohamed SURUR, and Abdi Hussein AHMED charged with participating in a conspiracy to traffic more than US$7 million in rhino horns and elephant ivory. In addition, KROMAH, CHERIF, and SURUR were charged with conspiracy to commit money laundering, and SURUR and AHMED were charged with participating in a conspiracy to distribute and possess with intent to distribute more than 10 kilograms of heroin. One of those charged is now in the US, another awaiting extradition in Senegal and two remaining Kenyans still at large, on the run.
This is not just important in terms of the action taken but how co operation across agencies and between public and private sectors and effective information sharing made a difference.
Attacking the Assets of Serious and Organised Criminality in the UK in the Absence of a Conviction by Helena Wood – published by RUSI
The paper published by RUSI, on June 10th 2019, authored by Helena Wood (RUSI Associate Fellow and formerly of National Crime Agency and Assets Recovery Agency) is a timely assessment of so called None Conviction Based (“NCB”) confiscation approaches focussing on the UK.
The introduction of the Unexplained Wealth Order (UWO) in 2017 by the UK government was intended as a key tool to tackle the national security threat posed by the the tens of thousands of persons linked to the approx 4,500 organised crime groups (OCGs) mapped in the UK and in particular to concerns raised around the proceeds of corruption some say find a too safe a haven in the UK. Continue reading
Virtual Currencies (VC) have come a long way in the 10 years since Bitcoin first emerged, born out of the financial crises and now a decade later they are considered part of the financial landscape. With more than 1,000 VC’s to choose from, tens of millions of customers use VC whether as a store of value, unit of account and/or as a payment medium. As with any currency, there are those minorities that use it to further illicit acts. Criminals have recognised that VC has unique properties that could potentially serve their interests in laundering illicit funds and evading law enforcement. Users of VC employ pseudonyms rather than names, funds can be transferred without intermediaries and across international borders as easily as sending email.
I like to think of “Red Alert” as an 800 page plus private travel guide through the teeming jungle of crimes, risks, regions, countries, criminals, terrorists, cases, banking products and services, laws, standards and regulations, & programme design relating to the complex work of financial crime.
Financial crime fighters face an increasingly difficult task, and an environment that is complex and dynamic. as such learning holds the key to success and will provide its own rewards. as Benjamin Franklin once said, “For the best return on your money, pour your purse into your head.”
As you read “Red Alert” either from the start to the finish, or by focussing on particular areas of interest consider the words of Confucius, who said, “Learning without thought is labour lost; thought without learning is perilous.”
This book tells the story of the rise and fall of Hermitage Capital, once the largest foreign investor in post soviet Russia, which made vast fortunes alongside oligarchs and criminals, sharing the spoils from the rigged privatisation of Russian Companies and the crooked markets that developed. As Hermitage made huge profits, the Company, its founder and CEO, Bill Browder, his associates and his Russian lawyers became targets, with Browder having his visa revoked and then his Russian Companies taken. According to Browder, he was taken out by powerful forces on instructions from the highest levels of the the Russian government. Browder tells of his losing battle, uncovering serious criminality by the Russian Interior ministry that took over his Companies, restated their reported profits and collected hundreds of millions of dollars in tax rebates.