ACCT 3305 · Money Laundering and Financial Crime

Led by Felix Aubrey Sharpley Simulacrum

1. Module 5 ○ Open

   Money Laundering and Financial Crime

   Led by Felix Aubrey Sharpley Simulacrum

   The question

   Money laundering and the UK financial-crime framework. The module covers the three-stage canonical model (placement, layering, integration), the typology (cash-business, trade-based, real-estate, shell-company, crypto, professional-services laundering), the principal UK statutes (POCA 2002, MLR 2017, Criminal Finances Act 2017), the FCA's expectations of regulated firms, the SAR regime and the DAML defence, the post-Russia-sanctions expansion of the financial-crime perimeter, and the forensic role across compliance review, SAR investigation, regulatory enforcement support, and POCA proceedings.

   Outcome

   The student can articulate the three stages of money laundering and the UK regulatory framework; can identify the customer-due-diligence obligations of a regulated firm under MLR 2017; and can structure a forensic AML investigation in response to a SAR or regulatory inquiry. (Money laundering and financial crime)

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   Practice scenarios

   Investigating a Suspicious Transaction at a UK Bank

   You investigate a suspicious-transaction pattern at a UK retail bank — £4.2m in 11 wire transfers from Latvian banks to a UK property-investment company with Russian-Belarusian beneficial owners, used for cash purchases of London residential property. The work tests whether you can apply the placement-layering-integration model, recommend immediate SAR and DAML actions, and defend the investigation against a relationship-manager's pressure to *trust the introducer*.

   Your goals

   • Apply the placement-layering-integration model: this case shows clear *integration* (funds emerging as UK property purchases) following *layering* (Latvian-bank intermediation, multiple counterparties).
   • Identify the regulatory questions: was the original CDD adequate (likely no — *family business in Russia* is not adequate source-of-wealth documentation); was the EDD applied (was the customer correctly classified as high-risk given the jurisdictional link); should the relationship have been terminated or further EDD applied as the activity escalated.
   • Recommend immediate actions: (1) suspend further activity on the account pending investigation; (2) file SAR with the NCA describing the pattern; (3) consider DAML application before completing any pending property transactions; (4) engage external counsel; (5) freeze the customer relationship within sanctions-screening protocols (check for OFSI sanctions designation against UBOs).
   • Recommend the longer-term forensic procedures: counterparty UBO verification (using corporate registries, OFAC and OFSI lists, beneficial-ownership databases like Open Ownership); transaction-pattern analysis across the customer's complete account history; review of the bank's CDD documentation and risk-rating decisions; review of the relationship-manager's notes for pre-existing flags.
   • Recommend the institutional implications: thematic review of similar customers (Cypriot or Latvian intermediation, Russian/Belarusian UBO link, recent expansion of activity); FCA notification considerations.
   • Frame as a 1,500-word AML investigation memo to the head of financial crime.

   Practise this scenario →