Sunday, 16 August 2015

The legal professional and ML/TF

I just finished reading a recent report on the vulnerabilities of the legal profession to ML/TF <  http://www.fatf-gafi.org/media/fatf/documents/reports/ML%20and%20TF%20vulnerabilities%20legal%20professionals.pdf  > . If you don’t have time for the full report ( I must admit I have not read all details myself ) try and read the executive summary and the cases. Definitively interesting – on a side note: the FATF site contains lots of interesting reports, it’s worth browsing some of the reports from time to time.
We all know that legal professionals play a crucial role in many financial transactions. It’s therefore no surprise that the report concludes “…that criminals seek out the involvement of legal professionals in their ML/TF activities, sometimes because a legal professional is required to complete certain transactions, and sometimes to access specialised legal and notarial skills and services which could assist the laundering of the proceeds of crime and the funding of terrorism. “. The report continues to describe the various methods that criminals deploy and contains over 100 case studies.
On page 5 the report contains a nice overview of ‘ the involvement of the legal professional ‘ in any type of transaction. Of course many legal professionals are trustworthy but there’s a large gray area between being alert and pro-active down to being willfully blind, corrupted or downright complicit.
The report concludes with recommendations for legal professionals and self regulating bodies (SRBs) that oversee the legal profession. Fact is though, that there is a huge difference amongst countries in terms of how strict these SRBs are and how much their influence and power is.
As a result – also because apparently many legal professionals do not do any CDD on their clients - a legal professional is often the weakest link in the parties involved in financial transactions.
I’m not sure if a call for more regulation and oversight is justified but the current situation can hardly be called satisfactory.
Suggestions and opinions are welcome! What do you think?


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