The prosecution alleged that Narita Bahra‘s client was one of three males who played a Leading role in this serious organised offence, involving eight co-defendants. The organisation unwittingly used Easyworld International Money Exchange Bureaus to launder in excess of £78 million. The police uncovered a factory based in London at which the funds were being laundered.
This was an unusual case in the current climate where money exchange bureaus are more stringently regulated by Money Laundering Regulations. The HMRC have made it clear that the onus now falls upon businesses at risk to implement anti-money laundering measures based on a ‘risk-based’ approach and assessment, namely; identify the money laundering risks that are relevant to their business; carry out a detailed risk assessment of their business, focusing on customer behaviour; delivery channels and so on, design and put in place controls to manage and reduce the impact of these risks; monitor the controls and improve their efficiency; keep records of what customer did and what business did.
Each business will need to consider: the types of customer they have; where the customers are based; assess customers’ behaviour; how customers come to their business; the products they sell or the services they offer; their delivery channels and payment processes, for example cash over the counter, cheques, electronic transfers or wire transfers; where customers’ funds come from or go to.
The onus falls upon each business to report suspicious money laundering and/or terrorist financing, and obtain consent from them to continue with the transaction.
Narita was able to limit her client’s accepted involvement to a figure below £1.5 million.
Narita was instructed by Priya Wader at Veja & Co Solicitors.
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