AML & Financial Crime in the Middle East

Caleb Hawkins 31.05.2016

The Compliance contract desk at Morgan McKinley is holding an AML & Financial Crime Seminar on Thursday 21st July with guest law enforcement and financial crime expert, Andrew Fleming.

Andrew has provided us with an insight into what to expect from the seminar and some discussion points for you to consider beforehand;

Andrew: As a law enforcement professional with over thirty years in policing I understand that financial crime is an area that represents an ever evolving threat landscape for companies with potential risks hidden in apparently innocent transactions or disguised or obfuscated through the involvement of gatekeeper professionals.

A recent example being Mossack Fonseca and the leaks that exposed tax evasion/avoidance, corruption, criminality and the involvement of the rich and famous utilising offshore companies and other structures to hide their wealth. Alongside this with this we have shell companies, light touch jurisdictions and terrorist financing. And in addition to the challenge of identifying suspicious transactions we have the burden of ever tighter regulation and the threat of hefty fines if we get it wrong and the potential prosecution of individual company executives.

As a consequence of the above, regulated entities are becoming more reliant on automated technical solutions, which create and analyse system generated reports to obtain key metrics on transaction monitoring. That data is utilised to provide stakeholders with visibility into the alert review process, to uncover data quality issues and address areas that need immediate attention. It is anticipated that by utilising these automated systems we eliminate human error and generate management information that is relevant, accurate and timely. Regrettably that isn’t always the case as organised crime networks and the gatekeeper professionals are also utilising methods to thwart our data analytics by New Payments Products and Services (NPPS) or utilising some very old ones to bypass our systems, we therefore need the expertise of SMEs and well trained staff as well as automated systems to counter this threat.

middle east magnified

In the presentation I will be providing on behalf of Morgan McKinley on the 21st of July 2016 I shall look at the financial risks in the Middle East and give examples of some unusual ways to launder money and pay a bribe, for example;

1.    Pretty camels 
2.    Prize breeding goats
3.    Hawala – Alternative Remittance Schemes (ARS)
4.    The use of light touch jurisdictions to transfer funds

I will also discuss the risks involved in the area such as;

1.    The prevalence of cash in high value transactions
2.    Conducting EDD on royal families and their associates
3.    A transient population – internally and externally
4.    The lack of post codes
5.    Terrorist financing – ISIS and its funding
6.    The prevalence of sanctioned countries and proscribed in the geographical area

When conducting business in a new region it is important to have an in-depth understanding of how business actually works within that particular country or region to ensure that you are not caught out by what may actually be common business practices. In a similar vein we also need to understand the potential threats that we may be exposed to be it sanctions, terrorist financing or bribery and corruption, so that we can ensure that we have the right governance and control structures in place to deal with them.

If you would be interested in registering for the event, please click here or email me at

We look forward to seeing you on Thursday, 21st July and discussing the Middle Eastern threat landscape in greater detail with you.

Connect with Andrew Flemming on LinkedIn

Caleb Hawkins's picture
Head of Compliance & Legal Temporary Recruitment