A long-awaited report regarding Russian influence, interference, and corruption of British institutions was finally published this week. Some posit the report does not reference anything previously unknown—to them this may be true, but to the general public the scale of Russian influence and interference may come as a shock.
More pointedly, this is all about money: The power behind money and those who bow down to those with money. The Beatles sung that “Money can’t buy me love,” which may be true, but it sure can buy you a lot of power.
Last year, I interviewed Bill Browder, the man behind the Magnitsky Act—now present in a number of countries around the world, including the United Kingdom. Browder confirmed that some time ago the Russians determined old-fashioned espionage involving spies, agents, and double agents was ineffective; after all, who can you trust? So, Russia got ahead of others and started to corrupt money and, subsequently, politicians, elections, and institutions.
From the perspective of the financial crime compliance officer, we were told to make it happen, because there was so much money to be made. Now the report confirms “it is widely recognized that Russian intelligence and business are completely intertwined.” Some financial crime professionals must now ponder just who are/were our clients?
The report specifically criticizes the unwillingness and failure of parties to ask questions regarding the source of wealth and/or funds. “The UK welcomed Russian money, and few questions—if any—were asked about the provenance of this considerable wealth.” Doubtless relationship managers and heads of wealth management asserted that Bank X or Firm Y undertook business with the Russians and, therefore, so should we. It was all about the money, and it would appear Russian President Vladimir Putin has used it well.
I recollect a time after 9/11 when a U.S. prosecutor advised me that the financial crime compliance officer had a very important role to play in stopping terrorism as well as the corruption of our governments and institutions. He said, “Anonymous money hides anonymous power, and that is a very dangerous thing.” In the event bankers determined not to establish the source or ownership of the wealth and the funds, then the ownership, control, and power were at best hidden and, worst still, anonymous.
The report makes direct reference to Russian finances in the United Kingdom: “… the illicit financial dealings of the Russian elite and the ‘enablers’ who support this activity.” Therefore, financial crime compliance officers need to take note and, where necessary, take action. It is now clear the money has never come “From Russia with Love.” On the contrary, the report asserts Russian money comes with sinister intentions, as Putin has welded the security services to his government and the economy, which he has weaponized.
More broadly, the report indirectly references the wider unwillingness of relationship bankers to ask intrusive questions of their important and wealthy clients. Banks and firms need to challenge and correct this culture, because being wealthy does not mean laws, rules, and requirements do not apply.
It can no longer be held that when big money talks, everyone walks to the tune of the rich elite. What we have learned is big money is attractive, but it is also high-risk and needs to be subject to enhanced levels of due diligence. If we do not ask the questions to understand and know who we are undertaking business with, then we will continue to provide the reduced level of service sought and appreciated by the likes of Putin, as well as corrupt actors and criminals with dirty money to clean.
The report will not make the Russians go away—indeed there is reference to damage limitation. This must extend to financial crime compliance officers asserting their bank is not run by the three wise monkeys (“see no evil, hear no evil, speak no evil,” aka “see the money, like the money, don’t ask questions about where the money came from”) Putin and his oligarch lieutenants are seeking.
Think about this in simple terms, and ask yourself if you would refuse to answer questions about your own source of wealth/funds. The answer must be no and, therefore, no one should perceive they do not need to answer such questions or, where necessary, provide evidence to support the answers.
Clean money provides transparency, certainty, and accountability, all of which supports clean politics and the democratic rule of law. Dirty money pays for dirty tricks, dirty campaigns, false narratives, and ultimately funds projects to kill opponents or others who threaten their totalitarian power. Think Salisbury, and then think about how Putin has ensured “Russian intelligence and business are completely intertwined.”
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