On their own authority

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Over a two-decade career in AML, one of the things I have noticed is the “normalisation” of the terms “money laundering” and “AML”.  When I first started out, I had to explain to everyone non-finance-y what money laundering was and what we were trying to do about it.  (One family friend wondered how I could hope to make a living telling people about one brand of car; she had mis-heard “fraud” as “Ford”.)  Nowadays you can’t watch a Hollywood film or Netflix drama or read a fast-paced thriller without stumbling across someone laundering dodgy money (usually wearing sunglasses and a sneer).  This makes me look good, of course: how prescient I was to choose a specialisation that would one day be so fashionable.  It was entirely by accident, I can assure you; I’m the contrary sort of person who prefers to be out of fashion.  But in many ways it is a good development, not least because money laundering awareness is spreading far and wide, with even organisations that are not [yet] required to do so by law putting in place their own AML procedures.

The latest to come to my attention is Aberdeen City Council.  Now, Aberdeen has had a few laundering headlines in its time.  In August 2014 Italian MEP Oreste Rossi announced that research done by the Transcrime Centre in Italy had shown that, in Scotland, “the Camorra stronghold is Aberdeen… where it controls the catering, public works, food retail and wholesale and property sectors” – although his view was later toned down in the November 2015 final report on “Organised Crime Infiltration of Legitimate Businesses in Europe”, which states simply that Aberdeen is one of the top three locations (along with Glasgow and Durham) mentioned in open-source material on organised crime groups.  That said, in August 2018 Scottish restaurateur Antonio La Torre was arrested in Italy on suspicion of mafia involvement – he was perhaps inevitably nicknamed “the Don of the Don”.  Those charges were dropped but he still faces firearms charges and must report daily to the police station in Mondragone, a seaside town just outside Naples.  In October 2018 Aberdeen solicitor Ian McDougall was struck off by the Law Society of Scotland after failing to answer for various AML failings in his firm and running off to (it is believed) Abu Dhabi.  And a month ago, Nigerian former professional footballer Jay-Jay Okocha was charged in Aberdeen Sheriff Court with money laundering allegedly relating to the proceeds of frauds perpetrated in Scotland in 2015.

Perhaps with these incidents in mind, on 30 June 2019 Aberdeen City Council’s audit committee approved a new “Anti-Money Laundering Policy”, which – although recognising that an MLRO is not a legal requirement for local authorities – nominates their Chief Officer-Governance as their, well, nominated officer.  They also supply a generous list of money laundering “flags”, including cash payments over £5,000, over-payments, and requests for overseas transfers to high-risk jurisdictions.  Is this perhaps a hint that our AML legislation, by not covering local authorities, is insufficient?  When an organisation voluntarily admits that it has a vulnerability to money laundering – albeit at a low level – and puts in place its own AML procedures, it certainly suggests that we could do more.