In a recent report, the UK's Financial Conduct Authority has used data that it has extracted from the firms it regulates to build up a picture of the frequency with which the UK's financial sector considers each of the world's jurisdictions to be 'risky' in relation to financial crime.

An FCA report, entitled Financial crime: analysis of firms’ data, contains a trove of information culled from the first "financial crime data returns" that the regulator commanded more than 2,000 of its firms to send it in 2016. Although many firms struggled to use their systems to gather the data, and although data collection techniques have since kept changing from year to year, making comparisons between years difficult, this initiative offers money-laundering reporting officers a view of the entire financial sector's perceptions of country risk for the first time. Far from being a blacklist of any kind, the resulting table of results is a blurry snapshot of British firms' decisions about how to allocate risk weightings.

The FCA asked firms to list the jurisdictions that they considered to pose a high "financial crime risk," a vague term that it never defines in the paper. This category of risk covers crimes such as money laundering, terrorist finance, fraud, the breaking of sanctions and market abuse. Deposit-takers such as banks and building societies, investment banks and life insurers contributed.

At the top of the 'miscreant' list are failed states such as Afghanistan (6th), Libya (8th), Syria (10th) and Somalia (15th); bugbears of the Americans such as Iran (1st), Russia (3rd) and Venezuela (19th); and some very poor countries. At the bottom, benefiting from maximum respectability, are countries with very white populations in the main, with the United States last on the list at 228th. Immediately before it are (in descending order of respectability) Sweden, Norway, Germany, France, Finland, Denmark and Canada. The UK is in 207th place.

Among the offshore jurisdictions that feature on the list are Panama (in 2nd place, just below Iran); Vanuatu (45th); the United Arab Emirates (74th); Belize (80th); the Bahamas (89th); the Marshall Islands (92nd); Cyprus (95th); the British Virgin Islands (99th); the Seychelles (103rd); the Cayman Islands (111st); Liechtenstein (112th); Nauru (114th); the Turks and Caicos Islands (116th); Antigua & Barbuda (117th); Kuwait (118th); St Kitts & Nevis (122nd); Latvia (123rd); Monaco (125th); the Cook Islands (127nd); Niue (128th); Trinidad & Tobago (131st); Vatican City (142nd); Bermuda (146th); Israel (149th); St Vincent & the Grenadines (150th); Gibraltar (152nd); Curacao (157th); Qatar (158th); Aruba (167th); Dutch Caribbean, where different (179th); Guernsey (180th); Isle of Man (182nd); Mauritius (183rd); Jersey (191st); Estonia (194th); Luxembourg (199th); Malta (200th); Sinagpore (204th); Switzerland (206th); Hong Kong (208th); and Ireland (213rd).

Institutions that submitted their returns had a total of 549 million relationships with their customers, of which 427 million (or 78%) were in the UK. Of these, the firms identified a relatively tiny figure of 120,000 ‘politically exposed persons’ or PEPs (people with prominent public jobs who might be in a position to exploit them for private gain) among their customers, 21,906 of whom they had 'onboarded' in the last year. There were 10,973 non-European-Economic-Area correspondent banking relationships.

According to the FCA's returns, the UK's financial sector collectively employs 11,500 full-time staff in financial crime jobs. The regulator guesses that the sector is spending more than £650 million annually in dedicated staff time to combat fraud, money laundering and other financial crimes. Even though these figures are dubious, this is the first time that a study of this kind has been publicised (albeit with anonymised information) anywhere in the world, as far as this publication is aware. Other jurisdictions ruled by Queen Elizabeth, such as Guernsey and Gibraltar, compel firms to send in such returns as well, however.

The Proceeds of Crime Act 2002 requires employees at regulated financial firms to report any knowledge or suspicions that they have that people are laundering money. 923,000 suspicious cases were generated internally in 2015-16 and sent to MLROs by automated systems and employees at all levels. After the MLROs looked at them, they reported 363,000 of these cases to the National Crime Agency, the UK's answer to the US Federal Bureau of Investigation. In addition, the MLROs made more than 2,100 suspicious activity reports that pertained to terrorist finance.