The British law firm of Howard Kennedy, having received the answer to a freedom-of-information question it posed to the Ministry of Justice, has discovered that only five people have been found guilty of offences against the Money Laundering Regulations 2007 since their inception.

The Money Laundering Regulations were introduced in 2007 and form secondary legislation that derives its force from the Criminal Justice Act 1987, as amended. They contain more than 20 offences (all of which have a custodial ceiling of two years) for which money-laundering reporting officers and bodies corporate can be charged. The first conviction under the new regulations was not until 2012, with four further convictions in the following three years. The FOI request also uncovered five more proceedings. These few convictions are not to be confused with convictions for offences in the Proceeds of Crime Act 2002, which are legion.

Ian Ryan, the head of business crime at Howard Kennedy, told this publication: “These findings are surprising, to put it mildly, particularly when we are repeatedly told that London is a haven for money laundering. It does seem that law enforcement is missing a trick and not using the full resources available to them to fight global financial crime. It is not entirely clear why there have been so few prosecutions, and the figures don’t reveal which industries the offenders came from. It may be that some of the offences are just too difficult to prosecute; for example, it is an offence for a regulated person to fail to make make an employee aware of the law relating to money laundering and not to regularly give training in how to recognise and deal with transactions which may relate to money laundering. One wonders how many estate agents or casino operators manage that every day."

Ryan added mischievously: “It may, however, be that everyone is happily compliant and the rumours of London as a money laundering haven are just sound and fury.”

The convicts are MLROs and possibly CEOs, although the FOI request did not go into specifics and did not even ascertain whether anyone received a custodial sentence. The transgressions are along the lines of bad 'KYC' controls, failure to train people properly, failing to monitor transactions etc.