Other Financial Crime Risks

Lawyers may encounter indicators of criminal activity that do not fall neatly within traditional AML or sanctions frameworks.

Examples include:

• modern slavery and human trafficking;
• organised crime;
• environmental crime;
• unlawful labour exploitation;
• trade-based criminality; and
• other conduct generating criminal property.

Such criminality often generates proceeds of crime and may therefore create money laundering, reporting or reputational risks.

You should seek to understand the underlying business activity, question unusual or exploitative arrangements and escalate concerns where explanations are incomplete, inconsistent or suggest that the matter may involve criminal property or other unlawful conduct.