| Money
Laundering: A Concise Guide for All Business
By
Doug Hopton
Published
by Ashgate Publishing, March 2006, $99.95, ISBN: 0-566-08639-5;
192 pages (hardcover)
Reviewed
by Jeffry R. Haber
NOVEMBER
2006 - In the April 2006 CPA Journal, I reviewed Guide
to U.S. Anti–Money Laundering Requirements: Frequently
Asked Questions, available as a free download at www.protiviti.com.
Having the book available online seemed to make sense in areas
such as anti–money laundering and terrorist financing,
where new rules and regulations are promulgated at a relatively
fast pace and the ability to update the content regularly
is an asset. I was curious to see how a hardcover edition
such as Money Laundering: A Concise Guide for All Business
would handle the accumulating body of regulation.
The
first thing that struck me about the book was that it is
a United Kingdom edition. The author has extensive background
in banking and anti–money laundering operations and
has formed a consulting company to help companies with the
prevention of financial crime, fraud, and money laundering,
and in some ways the book is as much marketing piece as
useful reference.
My
concern about whether a hard-copy medium can keep up with
a fast-changing industry was validated early. On page 21,
talking about countries that are on the “Non-Co-Operative
Countries and Territories (NCCT) List,” the author
states:
In
the review of October 2005 the list was reduced to only
the following two countries:
It
then goes on to say:
These
reviews will continue. While there are now only three
countries on the list … [emphasis added]
I do
not know what the third country is or why it wasn’t
listed. Nigeria came off the list in June 2006, after the
book had been published. Readers should be aware that this
field may change faster than publishers can keep up with.
As
a historical reference, the book is quite good in the early
pages, taking the reader through the various conventions,
the Financial Action Task Force (FATF), European and United
States legislation, and various regulations and requirements.
The book also includes useful appendices. The book would
be more useful for a U.K. than a U.S. business because of
the lengthy and detailed discussion of U.K. regulations.
Current
trends and expansions of the Bank Secrecy Act and the Patriot
Act, such as new requirements for money-service businesses
and, more recently, for the jewelry industry, are not covered
at all. This limitation in geographic scope and timeliness
makes the book ill suited for the U.S. For example, chapter
titles include the following, all of them U.K.-specific:
- “U.K.
Legislation”
- “Proceeds
of Crime Act 2002”
- “Proceeds
of Crime Act 2002—Other Areas”
- “Terrorism
Act 2000—Requirements and Offences”
- “Money
Laundering Regulations 2003”
- “How
to Implement in Practice the U.K. Anti Money Laundering
Legislation and Regulations—General Review.”
Ignoring
the fact that the book was out dated before it hit the shelves
and is geared to the British marketplace, it still could
be a useful primer for someone new to compliance with anti–money
laundering regulations or for a CPA who has a client who
has recently come under anti–money laundering regulations.
The book includes a lengthy discussion of “know your
customer” best practices, record-keeping, and reporting
practices that translate well to almost any business in
any country.
In
summary, as a historical archive of the development of international
anti–money laundering regulations, the book is quite
good. It covers and discusses certain basic elements of
an anti–money laundering program. Certainly for any
business located in the United Kingdom, or having U.K. operations,
the book will prove useful.
Jeffry
R. Haber, PhD, CPA, is an associate professor of
accounting at the Hagan School of Business of Iona College,
New Rochelle, N.Y.
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