The Case of the Disappearing Bank

July 17, 2019

In brief

  • For several years now, anti-financial crime (AFC) regulations have prohibited the operation of shell banks. A shell bank is a bank that has no physical presence in the jurisdiction where it is incorporated or licensed and no affiliation with a regulated financial group.
  • A trust does not have a “legal personality”. This means it cannot legally own assets. A trust can’t open its own bank account, execute contracts or become a shareholder in a company.
  • The TCSP acts as trustee for the Manolo Trust. Not a great deal of information is provided about how the trust came to be created.

This article has been featured on the International Banker

  • Sam Sheen
    Sam Sheen Financial Crime Adviser

Jail time looms for FATCA Responsible Officer

June 12, 2019

In brief

  • After witnessing the first ever successful US prosecution for Foreign Account Tax Compliance Act (FATCA) non-compliance, banks and Financial Institutions (FIs) will be thinking ‘What next?’ and considering their own FATCA programmes.
  • Events last week only serve to confirm that FIs are under the microscope. Organisations and individuals will be taken to task for non-compliance or deliberate avoidance.
  • The high level of international collaboration between a large number of cross-border agencies (including the City of London police and the FCA) is of particular note. International cooperation and effort will seamlessly result in successful prosecutions.
Contact Us

We're not around right now. But you can send us an email and we'll get back to you, asap.

Start typing and press Enter to search