Another Occasional Paper from RUSI, on 29th November, discusses the ways that cyber-criminals manage the proceeds of their crimes, from employing money mules to using services such as mixers to obfuscate the proceeds’ origins.  It offers recommendations for policymakers, law enforcement professionals and regulated entities to target and reduce these activities.  It says that some financial institutions are exploring innovative methods of detecting money-mule accounts, and that potential responses to the threat include either expanding the list of businesses subject to AML obligations on a case-by-case basis, as and when new business models arise, or using a flexible definition – for instance, of a ‘money-service business’ – that is capable of covering novel cryptocurrency businesses.  It also recommends that the UK government should provide guidance to regulated virtual currency exchanges on dealing with higher-risk counterparties, such as mixers of unregulated exchanges, and transacting in higher-risk cryptocurrencies, such as privacy coins. Such guidance will help exchanges assess the risks they face and prioritise mitigation measures.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s