Fraud/ Money Laundering 

Narita Bahra KC acted for the lead client tried on 78 million pound Money Laundering Conspiracy.

The factual matrix was highly unusual and complex: the prosecution alleged the organised crime group used unwitting regulated international money exchange bureaus to launder millions. The police located and uncovered the factory at which the funds were being laundered.

The case resulted in HMRC issuing publicised guidance that that the onus fell 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 secured the best outcome for her client, by limiting accepted involvement to a substantially lesser sum.