Kenneth Rijock in his blog on 26th July says that he has noted an increase of 90% in SAR filed in the last 6 months of 2017 compared to from the same 6-month period in 2016, and that 220 SAR were filed during the month of December, 2017 alone.  These details are said to be in the Interim Report for the second half of 2017 of the Financial Reporting Authority of Cayman Islands Government and, he suggests, may be due not only to a CFATF evaluation, but also the “Cayman Gang of Four scandal”.  The report itself can be found at –




On 26th July, FATF released this report, saying that professional money launderers are individuals, organisations or networks who, for a fee, help criminals launder the proceeds of crime.  FATF says that this is the first time the FATF is undertaking a project which concentrates on professional money launderers (PML) that specialise in enabling criminals to evade AML/CFT controls and sanctions and to enjoy the proceeds of their crimes.  The report –

  • looks at the techniques and tools they use so as to help countries identify and dismantle them – FATF assessments have revealed that many countries are not sufficiently investigating and prosecuting complex and third party money laundering;
  • identifies the key characteristics of the individual professional money launderer, the professional money laundering organisation and the professional money laundering network of associates and contacts that work together to facilitate money laundering;
  • identifies the various roles and functions that are necessary to operate a professional money laundering ‘business’. Using the case studies collected, it identifies a range of different money laundering organisations and networks, from money transport and cash controller networks to proxy networks; and
  • aims to help authorities understand how professional money launderers operate so that they can successfully target, prosecute and dismantle those who help make crime pay.

The report says that professional money launderers use a variety of money laundering tools and techniques such as trade-based money laundering, account management mechanisms and underground banking and alternative banking platforms.  To lend a veneer of legitimacy to their activities, professional money launderers may work with corrupt individual(s) who specialise in the provision of otherwise legitimate services (e.g. bankers, lawyers, accountants) in addition to their criminal money laundering activity.  Professional money launderers often work for more than one criminal or criminal organisation.  A successful prosecution of a professional money launderer can therefore potentially impact the activity of a number of criminal clients.