Tuesday, October 11, 2011

David Cameron's Acid Test of enforcement

A new report gives the lie to the Prime Minister's bromide that '...we're all in this together...'

Nearly all of Britain's biggest companies legally avoid tax in the UK, including the state-backed Royal Bank of Scotland and Lloyds Banking Group, according to new research.

The charity, 'Action Aid' found that 98 out of the 100 companies on the FTSE 100 base their operations in territories where there is low or no tax.

The heaviest users were based in the financial sector despite the industry's role in the economic crisis.

Britain's four biggest banks - HSBC, Barclays, Lloyds and RBS - have 1,649 tax haven companies between them.

Action Aid's tax justice expert Chris Jordan said: "Tax havens have a damaging impact on the UK exchequer, the stability of the international financial system, and vitally on the ability of developing countries to raise tax revenues which would lift them out of poverty and make them less dependent on aid.

"When multinationals use tax havens to avoid paying their fair share, ordinary people in both poor and rich countries are left to pick up the bill. Spending on doctors, nurses and other essential services gets cut for those who need it most.

"Tax havens might provide the lure of financial secrecy and low tax rates for big companies, but at a time when all countries are desperate for revenues, the UK government can't afford to turn a blind eye."

If this news wasn't nauseous enough, consider the bonus payments that bankers are now demanding.

In a recent survey by recruitment website eFinancialCareers, nine out of ten City bankers said they expect a bonus this year. Of these, nearly half anticipate more than last year; while one in ten expects their year-end payment to rise by 70% or more.

TUC general secretary Brendan Barber was reported as saying: "Banks have played a key part in bringing the economy back to the brink of recession so it's astounding that bankers expect any bonuses, let alone bigger pay-outs..."

"If the government refuses to challenge these multi-billion pound rewards for failure, the least taxpayers deserve is a bonus tax to help pay for the mess they are creating."

Despite several major banks warning that the eurozone debt crisis will hit profits this year, think tank, The Centre for Economics and Social Research, predicts that City firms will hand out bonuses totalling £7.2billion, up from £6.7billion last year.

Mr Barber said: "It makes you wonder what level of financial Armageddon is needed for bankers to not get a bonus."

What we all have to understand is that these grotesquely-paid parasites, who caused the international debt crisis in the first place, are getting their bonuses from money on which little or no British tax has been paid. So, where is their employers' justification for paying such high salaries and bonuses now?

We are always being told that without these payments, these incredibly intelligent people would go elsewhere. Well, now we can see there is no reason to keep them here, because their employing institutions aren't even paying any realistic tax anyway, so these threats are as hollow as are the morals of those who parrot this rubbish. Let the bastards fuck off to another jurisdiction, but make their hitherto automatic right to re-enter this country dependent upon a one-time windfall payment, cleared through H.M.Treasury, before presenting themselves again at Immigration!

David Cameron cannot sit back and contemplate this scenario without feeling very uncomfortable indeed. He has already had cause to observe what damage can be caused by a criminal under-class who had no reason to riot. If these disparities in social wealth become any more egregious, ordinary, decent working people who pay their taxes, seek to educate their children honestly, and who do not live in debt, but who find their jobs shrinking, their costs of living spiralling and their savings dwindling, will start to reconsider their position, and when that happens, their wrath will be terrible to behold.

We are now governed and ruled by faceless men and women in suits who sit in banks and boardrooms and bureaucrats' offices, and have no interest in us or our interests or our way of life. Banking decisions which govern us are made largely by people who have no interest in Britain, yet our Governments, of both colours, meekly acquiesce, and sign up to the bullshit they are fed.

David Cameron needs to go away and read G.K.Chesterton if he wants any assistance on what might lie in wait!

From the poem '...We are the people of England...'

They have given us into the hand of new unhappy lords,
Lords without anger or honour, who dare not carry their swords.
They fight by shuffling papers; they have bright dead alien eyes;
They look at our labour and laughter as a tired man looks at flies.
And the load of their loveless pity is worse than the ancient wrongs,
Their doors are shut in the evening; and they know no songs.

We hear men speaking for us of new laws strong and sweet,
Yet is there no man speaketh as we speak in the street.
It may be we shall rise the last as Frenchmen rose the first,
Our wrath come after Russia’s wrath and our wrath be the worst.
It may be we are meant to mark with our riot and our rest
God’s scorn for all men governing. It may be beer is best.
But we are the people of England; and we have not spoken yet.
Smile at us, pay us, pass us. But do not quite forget.

Monday, October 10, 2011

The World-Check Global Compliance Leadership Forum 6 - 7 October 2011

To Brocket Hall, Hertfordshire as an invited guest and speaker, to attend the annual Global Compliance Leadership Forum organised and produced by World-Check.

I have known the company since they started over a decade ago when they launched the world's first database for KYC compliance. Today they are rightly considered to be the leading global authority on resolving risk through targeted intelligence.

Now an integral component of the new Thomson Reuters Accelus Screening product, World-Check has been joined by the Northland Solutions Transwatch transaction monitoring software, to create a suite of end-to-end solutions that provide a comprehensive view of regulatory and legal risk, helping organizations manage Governance, Risk and Compliance globally, encouraging growth and innovation instead of bogging them down.

In the distinguished company of Rear Admiral Chris Parry, a specialist in Geo-Strategic Forecasting and Risk Assessment; Professor Alain Bauer, Professor of Criminology; Neville Tiffin, Global Head of Compliance of Rio Tinto; B.C.Tan, Head of Organised Crime Research for World-Check and Keith Packer, a former Commercial General Manager of British Airways, we spent two delightful and instructive days evaluating and analysing high-level issues of compliance with international regulatory demands.

My paper, which examined the issues surrounding narcotics and terrorist money laundering in Pakistan and Afghanistan, sought to evaluate the implications of the lack of meaningful aml systems and controls which still pertain in Pakistan, and how her failure to comply fully with FATF requirements has made her a real risk to international banks who could easily be induced to provide services to Pakistani high net worth individuals, or exchange-quoted companies.

When discussing money laundering typologies in Pakistan, it is an enormous mistake to start by thinking in conventional, money laundering terms.

In Pakistan, cash is routinely used, every day, as the traditional means of value transfer, and a very large number of even sophisticated, educated people will routinely withdraw the entire contents of their monthly pay cheque from the bank, once the cheque has cleared into their account, and hold it in cash.

It is not unusual to observe significant amounts of cash being used to pay for very large bills. When one checks into a hotel, even one of a very high standard, the clerk routinely asks whether the bill will be settled in cash or by the use of a credit card.

Pakistanis keep large sums of cash in their homes, and no-one thinks anything remotely untoward of such significant possession.

Therefore, when conventional money laundering methodologies are reviewed, but in Pakistani terms, the traditionally accepted truisms do not so easily apply.

For this reason, a major number of Western-style anti money laundering methodologies simply have no resonance in Pakistan because the criminals routinely keep the cash, and no-one is in the least bit concerned or suspicious if such sums are used to maintain their lifestyle.

This is not to say that money laundering techniques are not used in Pakistan, indeed, the more important requirement for illegally-acquired money in Pakistan is to have an acceptable way to explain its existence in cash form, as opposed to seeking to use conventional ways of laundering it. This does mean, however, that in many cases, the laundering methods adopt a form of 'reverse money laundering' where the activities of the person conducting the laundering activity are aimed at providing a putative legitimate provenance for the money, to give the cash a legitimate 'legend'.

We are dealing with a State which is very resistant to implementing meaningful aml systems and deliberately engineers a legally-instituted system of cross-border financial transfers, designed to allow the free-flow of all kinds of international currencies into and out of Pakistan, but without any meaningful questions being asked as to the source, provenance or ultimate destination of that money, a system which flouts international law and makes a mockery of any internal anti-money laundering proposals or initiatives, and which deliberately facilitates the financing of international drug trafficking and terrorist financing.

Addressing an audience largely composed of senior risk and compliance professionals is no sinecure, and a sharp debate ensued, identifying and recognising the problems associated with States like Pakistan and Afghanistan, and asking how they can safeguard their institutions from the risks of doing business with major Pakistani criminal elements or Afghan terrorist paymasters.

When discussing the difficulties associated with the narcotics connection which Pakistani money poses, it became easier to appreciate the dichotomy which financial sector practitioners have to face. Nevertheless, the debate did point up some potential solutions, which I have no doubt the World-Check and Thomson Reuters professionals present would have noted and will be working on.

This is the real value behind these fora, the chance to meet and discuss real-life problems with those who have most to lose from getting them wrong. This is where Thomson Reuters is really defining a new agenda of risk management, and opening up a whole new series of prevention mechanisms and tools. Working at this depth of intellectual challenge and with this degree of granularity defines a whole new scenario of sophisticated supports for the regulated sector.

As these kind of new products come on stream, they will quickly spotlight those 'so-called ' solutions which seem to promise much but deliver very little, and in time, they will be excluded from the market, as the new Thomson Reuters solution suites become recognised as providing significant added value.

Thank you World-Check for the invitation, thank you to the new friends and contacts I made, it was one of those events that was worth every minute!