Underground banking and informal value transfer systems—the basics—law firms
Produced in partnership with Laurence Howland of Buckles Solicitors LLP
Practice notesUnderground banking and informal value transfer systems—the basics—law firms
Produced in partnership with Laurence Howland of Buckles Solicitors LLP
Practice notesThis Practice Note explains underground banking, its history, current usage and associated risks. It is aimed particularly at law firms caught by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 and the associated requirements to identify and assess risk, maintain policies, controls and procedures to manage those risks and report activity giving rise to suspicion of money laundering or terrorist financing.
The Legal Sector Affinity Group (LSAG) published an Advisory Notice on Chinese underground banking and funds from China in March 2023. It highlights the risks posed in particular by Chinese underground banking and the expectations of the regulators in relation to effective due diligence and source of funds checks.
What is underground banking?
Underground banking is a broad term describing the provision of largely informal financial services, in particular money transfer, to personal and business customers, usually from within distinct ethnic groups. Underground banking is used in many communities and in diverse locations, but is most closely associated
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