Following the release of the SFO's annual report a few weeks back, Dominic Carman, noted legal commentator, discusses with Lawyer Monthly the lack of any mentions of Libor within the 76-page document. Given that David Green QC has previously stated that the SFO should be judged on their success in the Libor case, this is a startling omission.

A decade ago, the term LIBOR was rarely heard outside the City of London. But since the crisis of 2007/8, the London Interbank Offered Rate, which is used as a global benchmark to price more than $350tn of financial products, has become one of the most widely-used acronyms in British media.

On 19^th July, Andrew Bailey, chief executive of the Financial Conduct Authority, made a surprise announcement: he signalled the imminent death of LIBOR, confirming that the rate will be replaced by the end of 2021. The current situation is “not only unsustainable but also undesirable,” he said, after conceding that banks no longer wanted to participate in setting the rate.

By coincidence, Bailey’s announcement overshadowed news on the same day that a New York appeal court had overturned the convictions of two former Rabobank traders. In the first US criminal appeal related to US investigations into LIBOR manipulation, the duo - Anthony Allen and Anthony Conti, both from Britain - had been convicted in November 2015.

LIBOR’s demise may come as a welcome relief to David Green QC, director of the Serious Fraud Office, for whom the term has almost become omerta: he has developed a total silence on the subject. As evidence, one has to look no further than the SFO’s latest annual report and accounts for 2016-17, published less than a week before Bailey’s speech. Although the document stretches to more than 20,000 words over 76 pages, it mentions LIBOR only once – referring to the annual rate of interest in a fine to be paid by Rolls-Royce. Green’s lengthy overview makes no reference to LIBOR at all.

This is rather strange, given the synonymous relationship that had developed between the SFO and LIBOR over the last five years. Back in November 2012, shortly after he had taken over the SFO hot seat, Green was very keen to talk about LIBOR. Under questioning by MPs on the Justice Select Committee, he spoke confidently in asserting that the SFO should be judged on the outcome of its investigations into LIBOR. He informed them that the SFO had started its LIBOR investigations in July 2012, reversing a decision by his predecessor, and that a team of 40 investigators had been tasked to look into the activities of multiple traders at several banks.

Green’s bravado LIBOR rhetoric continued in a slew of subsequent media interviews. What then followed was a series of London LIBOR trials involving bank traders like the Rabobank duo. In the first of these, Tom Hayes was found guilty in August 2015 and received a 14-year sentence, later reduced to 11 years on appeal. Green expressed a “certain professional satisfaction” over the Hayes conviction, adding: “Plainly, it was a very important one. It was the biggest investigation we have ever done.”

However, in January 2016, five City dealers were cleared in a separate trial of helping Hayes to manipulate LIBOR. More followed. In July 2016, four former Barclays traderswere convicted of LIBOR rigging, receiving sentences of between two years and nine months and six and half years.

Green showed less schadenfreude at this result: “The key issue in this case was dishonesty. By their verdicts the jury demonstrated they were sure that the conduct of three of the defendants, Jonathan Mathew, Jay Merchant and Alex Pabon was dishonest. Senior LIBOR submitter Peter Johnson accepted he had been dishonest when he pleaded guilty to the offence in October 2014. The trial in this country of American nationals also demonstrates the extent to which the response to LIBOR manipulation has been international and the subject of extensive cooperation between US and UK authorities.”

However, in April 2017, following a six-week retrial, Stylianos Contogoulas and Ryan Reich, both former Barclays traders, were acquitted of LIBOR manipulation. The pair had originally been tried alongside the other four Barclays traders convicted in 2016.

Of the 19 traders charged in respect of Libor and Euribor manipulation, there has been one guilty plea, four convictions and eight acquittals. The remaining six defendants will be tried in April 2018. But of the four convictions, at least two are subject to appeal following fresh evidence at the Contouglas/Reich re-trial. Under cross-examination, the lead SFO expert witness acknowledged that his expertise was deficient when it was revealed that he had to text questions on technical points from the courtroom. The symbolic pressure of the two successful appeals in New York further undermines the SFO’s Libor investigations in London.

And so we come back to the strange absence of LIBOR in the SFO annual review. In a year filled with extensive news of LIBOR trials, it is as if they never happened. When questioned over LIBOR by another Parliamentary Select Committee last October, Green told MPs: “We don't go after the people. We go after the evidence and we go after the people the evidence points to.”

But according to its latest report, the evidence that the SFO has spent tens of thousands of hours and many millions of pounds investigating and prosecuting LIBOR traders has simply vanished. One important question remains unanswered: why?

Photo: Heathcliff O'Malley

The UK’s current government, in its recent electoral manifesto, has vowed to get rid of the Serious Fraud Office (SFO), and replace it with a separate entity post-Brexit. Below Dominic Carman, an expert legal commentator, explains the current situation and what we can expect.

Driven by Theresa May, the Conservative manifesto pledged to scrap the Serious Fraud Office and roll it into the National Crime Agency. In response, the legal friends of the SFO got together and lobbied heavily against its abolition. Their efforts, however, proved to be unnecessary.

When the general election ended with the government being re-elected with a reduced mandate, the Queen’s Speech that followed was dominated by Brexit: a host of pledges were hurriedly thrown on the bonfire, including the SFO merger plan. It was safe. At least for the time being.

But rather like the government which wanted to see the SFO being consigned to history, its authority was reduced and its reputation diminished: the sentence having been passed, it is probably only a matter of time before the final execution is eventually carried out.

For now, and for at least the next two years, Brexit is set to consume the attention of every cabinet minister, sometimes to the exclusion of almost everything else. This will include the PM and her successor as home secretary, Amber Rudd.

Fraudsters, however, wait for no-one. Recorded crime may have fallen by 25% since 2010 but fraud has increased.  Of the 11.5m incidents of crime recorded by the Crime Survey of England and Wales (CSEW) last year, 47% were fraud and computer misuse offences - a remarkable 5.4 million offences in total.

For all the intense debate over the number of police officers, virtually no mention of fraud was made by any politician during the election campaign and its aftermath - despite ONS figures showing that 4.5% of all adults were a victim of bank or credit card fraud, by far the most common crime affecting adults in Britain.

The first duty of government is to protect the life, liberty and property of its citizens. Although the nature of the threat changes over time the fundamental responsibility never does. As the Telegraph commented ‘The recent ransomware attack on the NHS is an indictment of a state that is not doing its job properly. Britain has a cybercrime problem; the next government must make tackling this an absolute priority.’

This was written only days before the Manchester bombing. Terrorism does, rightly, grab the headlines, but it too plays a part in the same deterrent narrative: keeping people and their property safe. Nowhere is this better exemplified than in the awful consequences of the Grenfell fire.

Tackling fraud, which may fund everything from terrorism to criminal self-enrichment, should be at the heart of this government’s agenda. While the immediate focus is inevitably on trade, the single market, the customs union and the transition period before Brexit is finally achieved, there is a real danger that fraud will be further side-lined and overlooked.

One of the less discussed consequences of Brexit is the potential loss of cooperation with different branches of the EU security network which help to combat fraud: national and EU-wide regulators and criminal investigation agencies. Less input from them will make investigations harder and prosecutions fewer, leading to even worse prosecution and conviction rates for the SFO.

The most senior British EU official, Commissioner Sir Julian King, recently spoke out to warn of the need for strong security cooperation in Europe. He said that it was vital for EU member states to work closely together to combat international cyber attacks, terrorists and hostile states and “be prepared for whatever the future holds”. Brexit, he confirmed, potentially risks future security cooperation.

Intelligence sharing may play a pivotal role in Brexit negotiations, we are told. But as the UK stands to lose international influence if deep security links with Europe are lost, there have been implicit indications that Britain may also use its highly valued intelligence services as a bargaining chip in Brussels talks.

Sir Julian described how the world is facing a “new and darker phase” in its relationship with technology, but added that countries must work collectively to tackle the threats confronting them.

He wrote: “Working with colleagues across the European Commission, we are determined to implement a plan for reducing our vulnerability to cyber threats by increasing our resilience to attacks, reinforcing security by design, stepping up the fight against cyber crime, investing in cyber security, and strengthening international cooperation.

“The interconnected world offers many opportunities for citizens, governments and public and private enterprises to make a positive contribution to society. But it also offers unprecedented opportunities to criminals, terrorists, and hostile states. We must be better prepared for whatever the future holds.”

Sir Julian highlighted Europol’s work exposing how sophisticated crime syndicates exploit online trade in illicit goods, adding that “online fraud is now the most common crime in the UK”.

This year, the SFO has been devoting its energies to negotiating Deferred Prosecution Agreements with Tesco and Rolls-Royce. It has taken a gamble in charging four Barclays senior executives alongside Barclays itself in an alleged fraud involving the bank’s dealings with Qatar during its £11.8bn fundraising during the financial crisis nearly a decade ago.

Looking ahead, we must be better prepared, as Sir Julian put it, “for whatever the future holds” in serious fraud, especially cyber crime.

The real suspicion is that the government, so all-consumed by Brexit, does not have the time, the political will or the capacity to devote to fraud as it should. Likewise, the SFO needs to look forward not back, and be ready to meet the challenges posed by tomorrow’s fraudsters. The task of doing that outside the EU seems set to become much harder.

Today is the implementation date for the fourth EU Money Laundering Directive (MLD4); time to see if preparations are up to scratch or whether a flurry of FCA fines will be issued.

In March we heard of the prosecution of an ex-HBOS (Halifax Bank of Scotland) manager and five others, all but one of whom were convicted for their roles in a complex and long lasting scam involving £245m of fraudulent loans. With mischief including cash in brown envelopes, exotic holidays, luxury yachts, properties in the sun and call girls, the more lurid details of the case read like the plot for a Hollywood film.

News today is that the prosecuted chiefs knew about their fraud and covered it up since 2008, according to evidence based claims by the police chief involved.

The loan scam fraud, which ruined several businesses that they were employed to save, was carried out by a gang of criminal bankers at the Reading branch of HBOS, led by Lynden Scourfield.

In February, Scourfield, another ex-HBOS banker and four associates including David Mills and Michael Bancroft were jailed for 47 years for fraudulent trading, corruption and money laundering.

Lloyd bank, which took over HBOS in 2008, has claimed to have been oblivious to the crimes ever since the beginning of the investigation by Thames Valley Police. But now the police force's commissioner Anthony Stansfeld believes he has evidence showing Lloyds’ bosses were aware since as early as 2008.

Stansfeld supposedly has an internal email from Lloyds’ risk department proving senior staff knew what was happening.

“The cover-up went on for ten years,” Stansfeld said yesterday. “An internal email in February 2008 within the risk department of HBOS clearly says that a major fraud had taken place within the Reading branch of HBOS, and that at least £200million had been defrauded from HBOS customers.

“Yet despite this evidence, the board of Lloyds… continued to refuse to accept that a fraud had taken place and pursued the victims.”

Speaking to Lawyer Monthly, Nick Titchener, Director & Solicitor Advocate of Lawtons Law had this to say:

“After the recent conviction of a number of senior bankers from HBOS back in February this year, one can see that the Financial Conduct Authority (FCA) is beginning to sit up and take real interest and probative action in the goings on in some of the big financial power houses. The coming forward of whistle blowers and the leaking of internal documents was undoubtedly critical in terms of how the case was proceeded with and will no doubt embolden others to come forward in due course. On this occasion, the setting aside of a £100 million compensation fund may not be enough to compensate those that lost out as a consequence of the fraud and it’s hard to think that at this stage it will appease the FCA either.

“There is an increasing appetite by the FCA and SFO to really go after both the bankers but also the financial institutions themselves where there has been identifiable failure, criminal or otherwise. This is no better exemplified by the decision of the SFO who have taken the bold, if not unprecedented step, of recently charging three of Barclays’ former top executives with Fraud related offences, all of whom will be appearing in court shortly. Whilst they may have distinct objectives, it is clearer than ever that the FCA and SFO are working together.”

Lloyds has £100million set aside to compensate victims, but Stansfeld says this won’t suffice. Lloyds Bank has also launched an internal investigation, led by retired judge Dame Linda Dobbs.

The Financial Conduct Authority has also launched an ongoing investigation.

Today is the implementation date for the fourth EU Money Laundering Directive (MLD4); time to see if preparations are up to scratch or whether a flurry of FCA fines will be issued. John Marsden, Head of ID and Fraud at Equifax had this to say.

The rise in high profile fines for failing to maintain money laundering defences proves that this issue is a key regulatory priority. Financial penalties for big players have pushed other industry giants to get their anti-money laundering procedures in shape. Aware that they’ll be in the FCA’s firing line, many big financial institutions will be ready to face a regulatory assessment of their MLD4 compliance processes.

The same can’t be said for smaller firms, where many have been slower on the regulation uptake. It’s arguably unfamiliar territory for the FCA to hone in on smaller businesses, but with anti-money laundering so high on the agenda economically and politically, this time could be different. While a traditional approach would target the bigger banks, smaller financial institutions could be subject to a series of warning shots in the form of audits, investigations and sanctions, should the regulator suspect they are failing to comply with MLD4. As a final step, a hefty fine could be issued which would have a significant financial impact on smaller businesses.

The UK will remain under the spotlight for domestic and international corruption, and regulated firms of all sizes need to ensure their protocols match the regulatory requirements. Companies have had ample time to accept and prepare for their role in the fight against money laundering as it continues to damage the UK economy. If they can’t demonstrate their compliance they risk significant financial and reputational damage. MLD5 is set to go ahead next year, heralding further changes – companies must ensure they don’t fall behind in their responsibility to tackle financial crime.

The FBI are investigating Bernie Sanders, former Democrat Presidential Candidate and Independent Senator from Vermont, and his wife, Jane Sanders, for bank fraud. According to CBS News, Senator Sanders and his wife have both called on attorneys to represent them during this probe, which has been ongoing since 2016, but kept hush.

During an interview in May with Burlington’s WCAX-TV, Sanders dismissed the allegations as “nonsense,” suggesting they are politically motivated.

Jeff Weaver, Sanders’ top adviser, said the pair have sought legal protection over federal agents’ allegations from a complaint in January 2016 that accused Ms. Sanders of distorting donor levels in a 2010 loan application for $10 million from People’s United Bank for the purchase of 33 acres of land for the Burlington College, of which she was president between 2004 and 2011.

According to Politico, prosecutors may also be investigating allegations that Sen. Sanders’ office improperly urged the bank to approve the funding.

Brady Toensing of Burlington, was a chairman for Trump’s [residential campaign in his state when he filed the claims surrounding the loan in 2016.

“I filed a request for an investigation in January 2016 and an investigation appears to have been started right away,” he said according to CBS News. “It was started under President Obama, his Attorney General, and his US Attorney, all of whom are Democrats.”

“My only hope is for a fair, impartial, and thorough investigation,” Toensing added.

Weaver describes Toensing’s claim that Sanders used his influence to push for the loan is a “political charge” that is “baseless” and “false.”

He also said, “the loan was approved by the financial board at the college,” in regard to Ms. Sanders’ supposed manipulation of the loan approval.

After a five-year investigation, the SFO announced that it has charged Barclays PLC and four former executives with conspiracy to commit fraud and the provision of unlawful financial assistance. The SFO charges relate to the bank's fundraising at the height of 2008's financial crisis; when it entered into funding arrangements with Qatar.

Former chief executive John Varley is one of the four ex-staff who will face Westminster magistrates on 3^rd July. Barclays says it is considering its position and awaiting further details.

Aziz Rahman, of Rahman Ravelli, believes the court proceedings could be a fascinating showdown between one of the UK’s biggest banks and the SFO; with neither side appearing to be prepared to compromise.

Prior to the general election, Prime Minister Theresa May outlined her intention to abolish the SFO; which may still be smarting from failing to convict two Barclays traders in April for Libor manipulation.

Mr Rahman said: “This case could turn out to be a defining one for the future of the SFO.

“The events of 2008 that led to Barclays striking a deal with Qatar were an extraordinary set of circumstances. Now we have another extraordinary situation where an organisation whose future has been under threat is looking to take on one of the biggest banks.

“No one doubts that arrangements between Barclays and Qatar were made. But while the SFO believes the arrangements that Barclays entered into were illegal, it appears that Barclays completely denies this.

“This year has already seen Rolls-Royce and Tesco admit wrongdoing and be granted a deferred prosecution agreement (DPA); which involves them meeting certain conditions in exchange for not being prosecuted.

“The fact that there is no hint of a DPA in this case – and that both the bank and individuals have been charged – indicates quite clearly that Barclays is in no mood to admit any wrongdoing.’’

Mr Rahman added that the SFO’s prosecution of both the bank and individuals that worked for it was surprising.

He said: “When it came to the cases of Tesco and Rolls-Royce, the SFO accepted that those two companies had undergone such changes to their senior personnel that they were no longer the same companies.

“Barclays has undergone a similar change but this, so far at least, has not counted for anything with the SFO.

“Both the bank and the four former employees who have been charged will now be working on the most robust defence cases possible. This may mean many arguments in court from all sides about whether the allegations surrounding Qatar were the responsibility of the bank as a corporate entity, the four men charged or, as the SFO believes, both Barclays and the individuals.

“The trial is certain to produce many arguments regarding the issue of an organisation’s corporate liability as opposed to the liability of individuals working for that organisation.’’

Once the Head Coach of Spanish football team Real Madrid and now of UK based Manchester United, Jose Mourinho has been accused of tax evasion fraud by Spanish authorities.

The accusations are in relation to his time as head coach at Real Madrid, where he allegedly defrauded Spain of €3.3m (£2.9m; $3.6m) in tax payments between 2011 and 2012.

According to the BBC, a prosecutor said he did not declare income from the use of his image rights in order to get an "illicit benefit".

There appears to have been quite a crackdown on tax fraud in Spain recently, as Portuguese champion Cristiano Ronaldo is also being charged with the same. He has been summoned to testify on 31^st July in a case which accuses him of evading €14.7m (£12.9m) in tax through offshore companies between 2011 and 2014, yet he denies the allegations and threatens to leave Spain.

The SFO has charged Barclays, its former CEO and three other former top executives with fraud pertaining to the funding of billions of pounds from Qatar during the 2008 financial crisis. The bank’s shares fell 0.5% on the news.

There have not been any other charges or investigations in regard to the financial crisis, but now former Barclays chief executive John Varley and three former colleagues – Roger Jenkins, Thomas Kalaris and Richard Boath, have all been charged by the Serious Fraud Office following a five-year investigation on the £11.8bn emergency fundraising Barclays ran in 2008.

The money raised from Qatar Holding, an investment bus for the Gulf state, meant Barclays could avoid taking bailout cash form the taxpayer.

This revelation was due to be announced months ago, and come amid pledges from the Conservative government to get rid of the SFO altogether.

According to the Guardian, Sarah Wallace, a partner and head of regulatory and criminal investigations at Irwin Mitchell law firm, said: “This is the most significant charging decision for the SFO in recent times, if not ever. In the past few years, Barclays faced an unprecedented number of investigations by worldwide regulators but this SFO criminal prosecution is the most serious.

“In taking on Barclays, one of the largest banks in the world, and its most senior officials who literally were at the very top, sends a very strong message that the SFO is now fearless in terms of the companies and individuals it pursues.”

The charges set amount to conspiracy to commit fraud by false representation surrounding a fundraising in June 2008, and the same for a fundraising that took place in October 2008.

They are also being charged with providing unlawful financial assistance through the loan.

Varley, Jenkins and the bank are set to appear at Westminster magistrates court at the beginning of July. Jenkins has confirmed via his lawyer that he will defend himself. He left Barclays in 2009.

Until the end of 2010, Varley was chief executive of Barclays. Kalaris, was responsible for the wealth management arm of Barclays. Boath is a former European head of the financial institutions group.

The FCA is also waiting in the wings to pronounce a decision from its own parallel probe into the 2008 capital raising. In 2013 the FCA said it would fine Barclays £50 million over the matter, but the investigation was deferred and reopened. The FCA has now stated: "We are pleased that this matter, which led to the stay of our own case, is now in the public domain. We welcome a fair and transparent hearing on the basis of the charges set out today by the SFO. We work closely with the SFO across a range of matters, in pursuit of our distinct objectives.”

Laith Khalaf, Senior Analyst at Hargreaves Lansdown told Lawyer Monthly:

“The SFO hasn’t pulled any punches, and Barclays now finds itself facing yet another regulatory battle. The bank is already facing litigation from the US Department of Justice and an FCA investigation into its current boss, Jes Staley, for trying to uncover the identity of a whistleblower. Skeletons seem to be jumping out of lots of closets at once for Barclays.

“The spectacle of former executives being paraded through court will do nothing to strengthen the credentials of the bank, as it continues to try to execute its turnaround plan. While RBS and Fred Goodwin recently avoided the ignominy of a court appearance, it appears that Barclays and its former CEO John Varley will not.

“However, the muted reaction in the share price highlights the fact that the SFO action was largely priced in, and more widely reflects the “misconduct discount” which applies to the banking sector. Litigation, fines and compensation payments have sadly become part and parcel of the banking world, and while many of the alleged offences took place a long time ago, the costs and reputational damage are still very much a live issue.”

In addition, Raj Chada, criminal defence solicitor at Hodge Jones & Allen, said: “There has long been a clamour for individuals at banks to be held accountable for the casino banking that led to the crash and the tax payer bailouts. The irony here is that this prosecution has nothing to do with behaviour that caused the crash but related instead to the terms of a bail out. Even more strange is that Barclays have found themselves in this mess as they eschewed a UK Government bailout and went to Qatar instead.

“No doubt questions will be asked about whether a deferred prosecution agreement (DPA) could have been considered in this case rather than a prosecution starting. The SFO have previously made clear that full cooperation is a key and it is not known what the position with Barclays was.

“Any fine for Barclays could be in the hundreds of millions.”

Tania MacLeod, Managing Partner at Rosenblatt Solicitors, had this to say to Lawyer Monthly:

“The news this morning that the SFO has brought charges not only against Barclays regarding its raising of funds from Qatar during the credit crunch, but also its former chief executive and 3 other senior officials, is a bold move by the SFO, the likes of which we have never seen before from events spinning out of the 2008 financial crisis.

“In the eye of the financial meltdown when the billions were raised from Qatar, the news that Barclays wouldn’t go cap in hand to the Government (aka the weary taxpayers) was widely heralded as a laudable move on the part of the bank’s senior management.  Barclay’s ability to seek finance elsewhere was seen as a commercially astute and enterprising move; after all isn’t that what banks are meant to do rather than ask for handouts?

“This morning’s news, which has been a long time coming, calls into question that commercial acumen and astuteness. The SFO is making very serious accusations against senior executives with otherwise impeccable career records. This case will of course run indefinitely and could even outlive the SFO itself if the plan to abolish it in the Conservative manifesto is implemented.”

With the 4MLD coming into action on 26^th June 2017 Aziz Rahman, Senior Partner at corporate fraud solicitors Rahman Ravelli has provided Lawyer Monthly with his comments on how businesses across the UK need to remain vigilant and inform themselves about the risks of a Money Laundering Investigation.

Corporate fraud legal firm Rahman Ravelli has advised businesses on how to spot money-laundering threats within an organisation and communicate concerns.

This comes after the 4MLD (Fourth Money Laundering Directive), which was agreed by the European Community in 2015 and is scheduled to be implemented on 26^th June, looks to deliver on former PM David Cameron’s intentions to crack down on money laundering in the UK.

The directive will secure data handling and introduce radical measures to help UK banks identify money-laundering threats and prevent terrorist financing.

It will also provide comprehensive reports on owners of corporate entities in a wide range of countries, producing a register of ownership that will help firms understand who they are doing business with.

The UK government has already made progress, enacting the legislation to bring about the register of ‘persons with significant control’ (PSC). Companies will need to begin populating the register from April 2017.

Aziz Rahman, Senior Partner at corporate fraud solicitors Rahman Ravelli, says that businesses need to remain vigilant and inform themselves about the risks of an investigation: “It looks to be a positive move from the UK government, and one that will hopefully make a difference to the number of businesses affected by money laundering.

“Transparency is key if it is going to work. Business leaders need to be training employees to recognise the signs and make them aware of the risks.

“An investigation into your business by a governing body such as the SFO can have a devastating effect.

“As the government looks to combat money-laundering operations, there is no doubt that new technologies will rise in opposition.”

Anti-money-laundering techniques are due an overhaul, in the UK at least. The 4MLD has come at the right time.

It has been reported that the anti-money-laundering divisions of UK banks squander almost £3 billion a year chasing false leads with outdated technology, according to research by AML technology experts Fortytwo Data.

The research reveals a need for more intelligent systems to deal with mass information stores and money-laundering threats that are getting increasingly sophisticated.

Aziz Rahman comments: “On a large scale, the measures implicit in the 4MLD will have greater influence if businesses are compliant with its requirements and carry out customer due diligence. It needs to be a two-way effort.

“Businesses also need to be aware of the latest technologies available. Without this awareness it is easier for money-laundering operations to go on behind the scenes.”

Rahman Ravelli has recently published a guide providing advice for businesses on how to be vigilant in the face of money-laundering, which you can see here.