The Dark Money Files

We look at the role of Authorised Corporate Service Providers (ACSPs) in the new regime at Companies House and explain why understanding both its strengths and weaknesses is important to anyone responsible for onboarding or monitoring UK companies, wherever in the world you work.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

One for the geeks! Changes in company formation levels are often use to justify/criticise different governments' economic policies.We go behind the headline figures to see if this is justified or not (HINT: not!).Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Ten years after the creation of the Office of Financial Sanctions Implementation, we look at how the UK sanctions regime has evolved—from early uncertainty to strict liability enforcement, sanctions list complexity, and the growing expectations on the private sector. Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Today we tackle some colourful risk lists or, to be a bit more precise, some black and grey ones, along with some strange differentials. Like how come the UK has a high risk third country list when there are no second countries in sight?Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In the second of a two part, end of year podcast, we continue to explain how we helped with a major BBC investigation into crime on the high street, involving the sale of illicit cigarettes and vapes, modern human slavery, people trafficking, tax evasion, corruption and money laundering.In this episode, undercover filming unearths a shocking story and we explain our part in finding some of the protagonists involved.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In the first of a two part, end of year episode, we explain how we helped with a major BBC investigation into crime on the high street, involving the sale of illicit cigarettes and vapes, modern human slavery, people trafficking, tax evasion, corruption and money laundering.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

We examine two recent final notices issued by two different regulators relating to two quite different enterprises and find a surprising amount of commonality in their thinking.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In the first of a new, occasional series, in which we sit down and chat to fellow anti-financial crime professionals, we kick off with Marit Rødevand from Strise to talk about AI and other new fangled gizmos.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

The UK Insolvency Service does a lot more than just oversee insolvencies and, in a recently published five year strategy document, they outlined some ambitious future goals which we thought were well worth a conversation.So we had one!Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

The FCA recently published new guidance specifically in relation to UK PEPs which we decided needed a closer look. So we did!Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we explain how we supported a major BBC investigation into a Hungarian organised crime group which was systematically forging wills and stealing the assets belonging to the estate from under the noses of the true beneficiaries.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode, we chat about a recently published report by Transparency International (see: https://www.transparency.org.uk/news/trust-issues-tackling-final-frontier-secret-property-ownership) and how it impacts on our ability to identify the true ownership of real estate in the UK (and elsewhere).Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

We bring you our latest deep dive into the world of crazy company incorporations and weird worldwide coincidences by way of North London, New Zealand and a much loved British sit-com.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

SARs!Search and rescue services?Subject access requests?Sudden acute respiratory syndrome?No - suspicious activity reports! That's what we are talking about this time. And there's a lot more to them than you might think.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we look at the FCA's latest thematic review of the National Fraud Database and money mule account detection tools and summarise what we think firms can take from it and what actions they might consider taking in response.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

"...Because every day we pay the price, we’re the living sacrifice"Taking inspiration from Bob Marley (sorry about the pun) we've done a little episode about scams and scammers (and some hints on how to spot them).Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we look at some of the links between three recent enforcement actions.We try to avoid the knee jerk reactions, and think a bit deeper about them.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

We turn our attention to the requirement to train relevant staff on all matters anti-financial crime.And if you're planning on training - your training needs a plan!Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we turn our attention to the tricky subject of outsourcing. We were going to get someone else to do it for us but we couldn't find a suitable candidate. :)Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Hot spots and intelligence 2In this second episode we look more broadly at the genesis of intelligence led policing, how it works and how compelling it is to draw parallels with our world of anti-financial crime.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we report on a recent visit to the European Crime Analysis conference in Copenhagen and draw parallels between the work of law enforcement and those working in compliance.Links referred to in the episode:Hot spot policingWolfsberg Group Statement on Effective Monitoring for Suspicious ActivitySend us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we explore some of the many different ways in which corporate entities can be used to engage in financial crime – although, as far as we are aware, they aren’t much use in removing stones from horse’s hooves.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

We dive into the details of OCGs and how they use corporate networks to launder their ill-gotten gains - and the clues they leave behind.And, rather appropriately, we also introduce the world to our new sponsor: https://riskalert247.com/Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we turn our attention to the thorny subject of proliferation financing and provide a basic explainer of what it's about and why it's important.The documents referred to in the episode can be accessed via the links below: FATF Guidance on PF risk assessment | https://bit.ly/4a9FKTM UK National Risk Assessment of PF | https://bit.ly/3JP2Lk7 | RUSI paper on PF in banking | https://bit.ly/4b4JpTU | European Commission guidance for EU operators | https://bit.ly/4doVhSrSend us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

With a forthcoming new requirement which makes it mandatory for UK payment service providers (PSPs) to reimburse the victims of some types of fraud, we look at the rules and how they are likely to play out.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Taking a slightly different direction from our normal content, we step back and look how the landscape of crime has changed over the years, and how in the process it has become democratised.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Following the news that nearly 800 restaurants in the UK have been cloned over the last few weeks, we thought we’d bring you the story behind the story. Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

It’s over to EUAfter a succession of episodes looking at the UK financial crime landscape, we shift our focus over the channel to Europe and the proposed changes to EU AML legislation.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Following some recent banking shenanigans, there’s been a rapidly introduced change in the UK law relating to PEPs.We think it needs to be put into a global context.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this second part of our review of the Economic Crime and Corporate Transparency Act, we look at the provisions relating to  failing to prevent fraud, crypto assets, information sharing and Strategic Lawsuits Against Public Participation (SLAPPs).Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Following the enactment of the Economic Crime and Corporate Transparency Act, reform is on the way to Companies House.But what does it look like and when will it happen?Here's our initial overview.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we walk the path from certainty to impossibility, via probable, possible and plausible.A conversation involving wind turbines, zebras and UFOs.You need to listen to understand!Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this second episode devoted to ultimate beneficial ownership, we delve into the world of exchange traded companies and the esoterica that is trusts.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we, somewhat belatedly, begin to tackle the thorny issue of identifying ultimate beneficial ownership. And we do so by pointing out that the “ownership” part of UBO is a bit misleading because it doesn’t cover control or influence.But then a UBOCI is a bit of a mouthful.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we walk through a recent, in-depth report into probable VAT and employment tax fraud reported on by Dan Neidle of the Tax Policy Associates, in partiucalr, how various different proessionals, individuals both here and abroad, and social media websites can be used, wittingly or unwittingly, to further the fraudsters aims.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

We couldn't let the recent Farage brouhaha with Coutts go by without some sort of comment.We've tried to chart a calm course through some choppy waters!Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we ask "What have the dinosaurs ever done for us?" It turns out, if you ask the right questions, it's quite a lot.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we take a (hopefully) user-friendly trip down the statistical road and explore some of the common pitfalls that can be encountered in preparing management information.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we look at the thorny issue of Management Information. What is it and what’s it for.Simple questions you might think, but often overlooked.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we bring you an update about regulatory expectations in respect of cash deposits. Along with a brief history of the UK’s Post Office dating back to the 17th century and the somewhat surprising news that it is still possible to make unlimited daily cash deposits of up to £20,000 with no form of identification.More information on KURE (brought to you by our sponsors Deep PoolmLtd) can be found at www.deep-pool.com. Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In the first episode of season 10, we turn our attention to an extraordinary story about online retail sales, China, VAT and HMRC.Despite all the apparent jargon, it is just an everyday tale of 11,000 companies all suddenly deciding to register to a private address where the owner had never heard of them.Which didn’t stop him being sent £500,000 in debt enforcement letters.And, in a first for The Dark Money Files, this podcast is now sponsored which will secure the ongoing future of the podcast and ensure we can continue to deliver a quality product.Here’s a link to our sponsor’s website: https://www.deep-pool.com/Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In the second part of our look at multiple choice tests we talk about how some fairly basic statistical analysis can help to validate their effectiveness. Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

Does your assessment programme correlate to individual performance? And if not, why not?Part one of a journey on the road to cognition.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we  talk about using our (metaphorical) little yellow bird as a predictor of the overall effectiveness (or lack of it) of your anti-financial crime framework.Would your KYC fall off its perch at the first whiff of trouble?Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we work through three of the smaller regulatory actions from last year which nevertheless contain nuggets of gold, successfully panned by Ray.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In something of a departure from our normal content, we review the passage of the Economic Crime and Corporate Reform Bill through the UK parliamentary system and use the opportunity to explain in more detail just how the scrutiny and passing of legislation works in practice.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In this episode we weave together crypto, courts and controversy when Sam Bankman Fried meets the Court of Justice of the European Union and a millionaire underwear Baroness. Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

It’s been a little while so we thought we’d do a bit of a catch up on some recent publications from Wolfsberg, the FATF and the Finnish FSA.Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

In our final part of our look at fraud, we explain, in general terms, current approaches to how best to compensate the victims and deny the fraudsters (as well as explaining briefly, why the gap since the last episode).Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/

We interrupt our suite of podcasts on fraud to bring you a special episode relating to the human cost of fake company incorporations.Working with various different media outlets, we’ve helped bring to light some of the stories relating to people who unwittingly fall foul of fake company incorporators.Listen, for example, to this recent episode of BBCs You and Yours: https://www.bbc.co.uk/programmes/m0019z2g Send us Fan MailSupport the showFollow us on LinkedIn at https://www.linkedin.com/company/the-dark-money-files-ltd/ on Twitter at  https://twitter.com/dark_files or see our website at https://www.thedarkmoneyfiles.com/