Moorwand is committed to implementing industry-leading standards to ensure effective antimoney laundering processes are in place across all Moorwand products and services. Moorwand has established an Anti-Money Laundering Programme (“AML Programme”) for this purpose. The objective of the AML Programme is to ensure that money laundering risks are appropriately identified and mitigated by Moorwand and its Programme Managers (“PMs”).   Moorwand’s AML Programme is designed to provide a system of risk-based controls to facilitate thorough due diligence, the identification, mitigation and management of Money Laundering, risks and other financial crime considerations.


What is Money Laundering?

Money laundering refers to the process of making large amounts of money made from illegal sources, also known as ‘dirty money’, look ‘clean’ or legitimate.  Money laundering is a crime that has far-reaching consequences for a number of stakeholders, including banks, fintechs, and payment solution providers such as ourselves.   It is a criminal offence to acquire, possess or transfer funds (offences subject to s327, s329 and s328 of The Proceeds of Crime Act 20025 (“POCA”) respectively) which you know or suspect derive from criminal activity.   Information from The National Crime Agency revealed that over £100 billion is lost to money laundering each year in the UK alone.   According to the United Nations, between $800 billion and $2 trillion was lost to money laundering in 2020. This is the equivalent of between 2-5% of global GDP.


How Does Money Laundering Work?


A typical money laundering scheme


1. Placement — Here the ‘dirty money’ that has come from illegal activities is entered into a legitimate financial system and converted into monetary instruments. For example, cash funds are used to buy chips in a casino, converted to cryptocurrency or deposited into an account at a financial institution. This is arguably the most difficult stage for criminals to navigate and the best stage for the authorities to try and stop them. Placing large amounts of money in our system will often cause suspicion.

 2. Layering — This is when money is moved to mix it in with legitimate funds and hide the illegal origin. For example, criminals may create false invoices, offshore accounts, and shell companies in order to create an incredibly complex web of transactions that make it nigh on impossible to trace the money back to illegal activity. The more layers there are, the harder it is to detect the origin of the funds.

3. Integration — The ill-gotten gains are now absorbed into the economy. Examples of this include the purchase of real estate, art, and watches. Once the above stages are complete, the money is considered ‘clean’. Therefore, the money returns to the money launderer from a seemingly legitimate source.


Specific Money Laundering Tactics

Within these three stages, which often overlap and aren’t always set in stone, are other tactics criminals use to ‘wash’ their money.

Invoice fraud

This is the most common technique used for transferring dirty money. An example is when a criminal contacts a company saying that the supplier payment details have changed. They then provide alternative, fraudulent details in order for you to pay them money.


This is when a large sum of money is broken down into smaller, less suspicious transactions, below the reporting threshold. The illegal money is gradually deposited in a bank account over a long period of time.

Offshore Accounts

Laundered money is often hidden through offshore accounts as this process easily hides the identity of the real beneficial owners and is a way to evade paying tax to HMRC. Offshore accounts are bank accounts opened in a country outside of where an individual resides.

Carrying Small Sums of Cash Abroad

Money can be laundered by carrying small sums of cash abroad below the customs declaration threshold. Then this cash is paid into foreign bank accounts before sending it back home.


The advent of cryptocurrencies has opened up a new door for criminals to clean their money. Cryptocurrency coins can be bought with illegal funds, which are then sold on an exchange, giving the illusion that the money from the sale of the coin is legitimate.


Who Can be Liable for Money Laundering Charges?

Money laundering is a complex crime that requires more than one person for it to be successful. Consequently, if a money laundering charge is brought against a suspected criminal the following people can also be liable to be charged in conjunction:

— Financial institutions

— Credit Institutions

— Accountants

— Tax Advisers

— Legal firms

— Casinos

— Auctioneers

It’s important to note that in many cases ignorance will not be an adequate defense, therefore it’s vital that any of the above people are up to date with money laundering tactics so as to not fall foul of the law.



AML stands for Anti Money Laundering. It refers to the strategies and tactics fintechs, organisations and regulators use to combat money laundering activities.

These include:

Hiring a dedicated AML team — This team can consist of people such as Data Scientists, Fraud Specialists and AI experts.

Building and iterating AML software — Updating older rules-based systems, embracing AI are two key components of this.

Implementing legislation — Specifically legislation that increases the difficulty of money laundering, e.g. large transaction reporting.   Fintechs and financial institutions face numerous challenges when trying to combat money laundering:

— More sophisticated criminals

— Increased Regulations

— Expanding data volume

— Digitalization of products and more complex payment streams


The Consequences of Money Laundering

Money laundering, whilst being an illegal activity with a slim chance of extremely high rewards, also has tremendous likely downsides for all involved.

These include:

A damaged reputation — Being associated with money laundering on any level can have a significant negative impact on a company’s reputation. Customers and partners can lose trust in the integrity of the organisation’s operations.

Legal action — Being charged or found guilty of any activities relating to money laundering can prevent that person or business from operating again, and could possibly lead to jail time.

Financial penalties — Regulators can hit organisations with significant fines that could end up in the hundreds of millions, even billions sometimes.


Moorwand’s Commitment to Anti Money Laundering

Here at Moorwand, we have a comprehensive anti-money laundering policy which we strictly adhere to.   This protects our clients, our client’s customers and ourselves from any negative repercussions. Find out more about how Moorwand can help your business enhance their financial activities today.

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