CHAPTER 5

Money Laundering Deterrence : The Challenge of Applying a Risk-Based Approach

David Blackmore

MHA

Introduction

The UK anti-money-laundering (AML) regime currently in place is and will remain a challenge for all concerned. There are no guarantees it will succeed in its declared objective of deterring, even reducing, money laundering and terrorist financing. This truly is at the very sharp end of the risk matrix for firms, regulators, customers, and UK plc.

It is important not to overlook the fact that the legislative framework in the UK is one of the most draconian anywhere in the world’s developed economies. The combined provisions of the Proceeds of Crime Act, the Serious Organised Crime and Police Act and the Terrorism Acts, together ...

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