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The mission of MACO is to create professional education and knowledge standards for Compliance Officers serving in the Maltese financial services sector, enrich the professional culture and enhance both Maltese and international relations and alliances.

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Insight News

November 9, 2018

Hidden in plain sight – The concealment of beneficial ownership

The Financial Action Task Force (FATF) published a recent report that looked into the techniques employed by criminals to conceal the ownership and control of illicitly obtained assets by using a combination of layering and direct ownership chains. In many cases the beneficial owner will maintain some level of direct control over a scheme, usually involving a family member or business associate, but it is imperative that they are able to conceal their own identity. The report explained that schemes designed to obscure beneficial ownership often employ a ‘hide-in-plain sight’ strategy by leveraging global trade and commerce infrastructures to appear legitimate. However, this visibility does not equate to transparency, and many of the tools that were designed to encourage business growth and development, such as limited liability corporations and nominee directorship services, can be used to facilitate money laundering, tax evasion, and corruption. The globalisation of trade and communications has only increased this threat, and countries now face the challenge of enforcing national laws in a borderless commercial environment. Let’s take a closer look at how these legal arrangements and professional intermediaries help criminals conceal their wealth and illicit assets. Shell companies One of the key elements used to conceal beneficial ownership is through an incorporated company with no operations, business activities or employees, commonly known as a shell company, through which illicit money can be passed. Layers of ownership linked to the shell company will be put in place, with intermediaries and third parties, which can include spouses and children as well as other personal or business associates, who will exercise control of it on behalf of the beneficial owner. Trust and company service providers The use of professional intermediaries is also quite common in concealing beneficial ownership. For example, a trust company or a legal professional can assist a criminal by establishing legal arrangements and bank accounts through which criminal funds can be moved. Legal trust accounts offer a means to disguise beneficial ownership too, and the legal professional privilege can also offer a significant barrier to authorities trying to recover beneficial ownership information. Trust and company service providers (TCSPs) represent a significant proportion of the professional intermediaries who are establishing legal persons and legal arrangements on behalf of their clients. They were also found to be more likely to provide services to clients internationally, which plays conveniently into the hands of anyone looking to conceal beneficial ownership overseas. TCSPs who were found to be complicit in their involvement, were identified as being more wilfully blind than fully complicit. This is because their services are vulnerable to exploitation by criminals (and potentially other professional intermediaries) involved in an illicit scheme.  Designated non-financial businesses Designated non-financial businesses and professions (DNFBPs), e.g. casinos, real estate agents and dealers in precious metals/stones, can also help to add a layer of concealment to the beneficial ownership details, which will assist the criminal in concealing their identity. More often than not, the DNFBPs will get involved knowing they are playing a role in the concealment of the proceeds of crime, however, occasionally they may be unwitting participants. This highlights the important need for more effective regulation of DNFBPs, as well as professional intermediaries, to encourage increased awareness in the sector, and to reduce the likelihood of some of these becoming unwittingly involved. Some of the ways in which these vulnerabilities can be addressed have been identified by the FATF report and include: consideration of the role of nominees, including measures that may limit their misuse the need for regulation of professional intermediaries in line with the FATF Standards, and the importance of efforts to educate professionals on money laundering and terrorist financing vulnerabilities to enhance awareness and help mitigate the vulnerabilities associated with the concealment of beneficial ownership further work to identify possible solutions or measures to prevent the misuse of legal professional privilege (LPP) to conceal beneficial ownership information, including through the provision of enhanced training and guidance material for legal professionals ensuring financial intelligence units have access to the widest possible range of financial information increased sharing of relevant information and transaction records to support global efforts to improve the transparency of beneficial ownership further work to understand what can be done to improve the quality and timeliness of the cross-border sharing of information, including through mutual legal assistance ensuring, for countries that make use of registers of beneficial ownership, and for all countries’ company registers, that there is sufficient resource and expertise associated with their maintenance – this is to ensure that the information recorded in the register is adequate, accurate, and up-to-date, and can be accessed in a timely manner the need for countries to consider and articulate the vulnerabilities and threats relating to domestic and foreign legal persons and arrangements, the domestic and foreign intermediaries involved in their establishment, and the means by which criminals may exploit them to facilitate money laundering and other criminality. A broad theme underlying all of these issues is information, including possible ways to improve the reliability, access and mechanisms to share that information more effectively at domestic and international levels. Further reading:  Are Bitcoin addresses shell companies in disguise? Beneficial ownership : A new era of openness? (Gibraltar) Is the sun setting on BOTs tax haven status?     This article forms part of the   #BigCompConvo   - Join us as we explore and debate the latest challenges and issues facing you and regulatory and financial crime compliance professionals all over the world. If you’d like to contribute an article as part of the   Big Compliance Conversation   get in touch with us at
November 5, 2018

Guy Fawkes Night: Celebrating counter-terrorism

Guy Fawkes Night celebrates the failure of the Gunpowder Plot to kill King James I at the Palace of Westminster on November 5, 1605. There’s something modern, and therefore something we recognise, in the Gunpower Plot: it featured a small group of fanatics, whose plan was wildly ambitious, violent, and spectacular in its execution; the plotters were inspired by a fervent religiosity, selected a well-known target, and were rigid in the assertion that their cause was just. These are the hallmarks of contemporary terrorism, and it was viewed with the same spirit of fear and disgust as it is today, but Fawkes’ capture means we can celebrate what became one of Britain’s great counter-terrorism successes (the division of Fawkes’ remains and their disposal to the ‘four corners of the kingdom’ an early instance of state public relations). The man who has become synonymous with the attempt was not the architect of the plan. Indeed Fawkes’ guarding of the gunpowder beneath the House of Lords points to the fact that he was a trusted and reliable participant, but not its conceiver, as is commonly imagined – that dubious honour belongs to Robert Catesby.  A subplot involving kidnap, an anonymous tip off that led to the plot’s unravelling, and an ending which included a siege at Holbeche House in Staffordshire, where 200 soldiers surrounded Catesby and the few remaining conspirators, suggest a cinematic quality that the twenty-first century world of cyber surveillance simply cannot match for theatricality. Modern terrorists and their methods and motivations are striking similar to those on display by the gunpowder plotters, and writers today question the extent to which Fawkes would be considered a terrorist . The grievances have shifted and altered, but the same tropes are all in evidence. In Newsweek , Christopher Dickey coined the acronym ‘TNT’ in his summary of the three ingredients that make up a terrorist: testosterone, narrative and theatre. Testosterone reflects the overwhelming prevalence of young men who make up terror groups. Fawkes’ age at the time of his death, 35, is higher than the typical age for contemporary terrorists but not far off it (the average age of the 9/11 hijackers was 24, though the eldest Mohammed Atta, one of the ringleaders, was 33).   It is in the folly of youth, where reason and restraint are lost in a fug of hormones, when impressionable would-be terrorists are groomed or moulded. A substantial amount of them will not have been born in to their cause, and indeed Fawkes converted to Catholicism with the familiar zeal of the convert . In a manner similar to that of jihadis going abroad in what they perceive as holy war, Fawkes fought for the Catholic Spanish in their war against Protestant Netherlands. The ‘n’ is for narrative, the story of persecution and self-pity and resentment that terrorists tell themselves to incubate and buffer their ideologies. There may be foundation to some grievances, as in the persecution of Catholics in England under Elizabeth (who had been made persona non grata by Pope Pius V in 1570), but terrorists’ narratives are absent of the nuances that constitute a balanced and reflective assessment of history. One characteristic of the ‘narrative’ aspect, identified by Walter Lacquer, is that terrorists are unlikely to have been on the receiving end of injustice directly (Fawkes certainly wasn’t). It is also not unusual for them to come from well off or comfortable families – Osama Bin Laden being the example par excellence – a criteria again Fawkes fits.     The final ‘T’, theatre, was exactly what the foiled explosion intended to vividly embody, both in the visual spectacle the bomb would unleash but also in the inherent drama of committing regicide and setting ablaze the symbolic home of the British government. Had he been alive today under similar conditions, Fawkes would probably be sitting in Belmarsh, nursing his grievances. Terrorism’s grip on the national consciousness means that individuals like Fawkes exert a strong pull on the collective British imagination. The popular refrain asks us to ‘remember’ this date, and far from nostalgia, perhaps our future counter-terrorism efforts rely on doing exactly that.
November 1, 2018

Meet an ICA member: Jonathan Harris-Moss

Creativity and compliance Jonathan Harris-Moss (Channel Governance Manager at BT Enterprise Corporate)   recalls the importance of ICA Diploma in Governance, Risk and Compliance to his learning journey. If I’d been asked earlier in my working life to consider a career in compliance, I might have turned my nose up on the grounds that I was trying to become one of those ‘creative types’, unrestricted by rules. Fast forward several years and here I am in 2018, a fairly new entrant into the governance, risk and compliance (GRC) profession. Having stumbled across the world of GRC, I have discovered that I had a number of attributes that lend themselves well to making the most of that move. For me, however, most of these attributes remained uncalibrated, somewhat untested and only modestly developed. Cue the ICA Diploma in Governance, Risk and Compliance… The ICA Diploma framework was to be a vital part of my formal GRC education. International Compliance Training (ICT) was integral to delivering this, providing an in-house course for our cohort to learn and develop together. Having not formally studied for a few years, there was definitely a sense of anxiety amongst our cohort. Our first of four workshops was enlightening. Our tutor, Rod, urged us to discuss the syllabus themes, but did so in such a way that encouraged analysis, humour and the sharing of experience. It was also profound – we were all once more ‘learning to learn’. We challenged, argued, and grumbled. Travelling home from London, my head hurt, but I felt energised and excited to share what I’d learnt. The super thing, however, is that when you tire of one leaning method, you can switch to another – pushing back the office chair to watch one of the many ICA webinar videos was welcome ‘therapy’. Slowly, but very surely, the dots began to join up and I was convinced that February’s deadline for the first 3,500-word assignment would be achievable. The BT Enterprise cohort had regular ‘virtual’ meetings to discuss our study methods and it became fascinating to see how we’d each interpreted the tasks differently. Whatever the correct answer, there’s much selfish solace to be taken in knowing that you’ve got exactly the same challenge as everyone else. I’m immensely satisfied with my final Diploma result, but my ‘credentials’ goal seems to have matured along the way. I’m somewhat more inquisitive about what I do with my experiences and how I keep my learning alive and fresh, as opposed to simply acquiring it. My colleagues also seem to feel this way and there’s a developing uniqueness about helping GRC mature and evolve. Belonging to a professional body is also a substantial benefit, which is for me, arguably more significant than the Diploma itself. Having now joined as an ICA MICA member, I’m beginning to understand the responsibility I have within the GRC profession, to contribute towards its innovation and development. Now that I have a more developed and tested understanding of how GRC fits together – both between its component parts and within an organisation – I see the scope for creativity as being enormous.   -   Meet other likeminded ICA members: Muhammad Rizwan Khan,  Chief Compliance Officer James Leake,  Global Head of Financial Crime Risk Screening for AML & CFT Anastasia Savvateeva,  Anti-Financial Crime & AML Compliance Officer   Do you want to get involved in our ' Meet a Member ' campaign? We’d love to feature you in our ICA Insight series, and in inCOMPLIANCE®! Getting involved is a fantastic way to raise your profile within the ICA and an opportunity to interact with your fellow members, as well as those interested in entering the field.   Find out more and let us know you are interested by emailing This article forms part of the  #BigCompConvo  -  Join us as we explore and debate the latest challenges and issues facing you and regulatory and financial crime compliance professionals all over the world. If you’d like to contribute an article as part of the  Big Compliance Conversation  get in touch with us at

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