The Home Office has published the latest UK Anti-Corruption strategy. It builds on the 2017-2022 strategy and includes 123 commitments to tackle and build resilience to corruption. It complements and builds on the...
Category - Financial Crime Prevention
Emma RadmoreTreasury publishes annual AML supervision report
HM Treasury has published its annual report on AML and CFT supervision. Key points include: recognition that the reform of professional body supervision so that the FCA will become the direct AML supervisor of...
UK imposes sanctions on terrorist group
The UK has imposed an asset freeze and director disqualification on an individual and a group suspected of belonging to and supporting organisations involved in terrorism in India. It has used powers under the Domestic...
G7 publishes cyber response guidance
G7 has published its guidance on fundamental elements of collective cyber incident response and recovery in the financial sector. The Cyber Expert Group chaired by the US Department of the Treasury and the BoE has...
FCA charges former bank director with fraud and forgery
The FCA has charged Henrik Schliemann, a former director of a merchant bank, who also held the Compliance Oversight and MLRO roles, with 9 offences relating to fraud and forgery. It alleges he transferred millions of...
FCA censures Institute of Certified Bookkeepers for AML supervision failings
The FCA has censured the Institute of Certified Bookkeepers (ICB) for serious deficiencies in its AML supervision. The action is the FCA’s first ever enforcement outcome against a professional body supervisor...
Laura WilesSFO updates guidance on corporate compliance programmes
The SFO has updated its guidance on evaluating corporate compliance programmes. The guidance looks at: when the SFO may want to look at programmes – it does this in 6 situations, mainly when it is considering some...
FCA publishes skilled persons data for Q2 2025
The FCA has published its latest data on skilled persons reports, covering 1 July – 30 September 2025. During this period, the FCA commissioned 6 skilled persons reports: 2 reports related to insurance, 1 to...
SFO launches first major crypto investigation into $28m scheme
The Serious Fraud Office (SFO) has launched a first-of-its-kind investigation into suspected fraud in a $28m crypto scheme. It has asked investors in the scheme to come forward with any information they hold about the...
NCA publishes guidance on SARs and DAML requests
The UK Financial Intelligence Unit (UKFIU) – an independent unit within the National Crime Agency (NCA) – has published guidance on best practice for Suspicious Activity Reports (SARs). The first two...
PSR pleased with CoP effect
The PSR has published its latest fraud prevention data, and noted that now that nearly all firms that use FPS also use CoP there has been a marked improvement in fraud prevention. Since CoP was expanded beyond the...
JMLSG consults on guidance updates
The JMLSG is consulting on some clarifications to parts of Chapter 3 and 6 of Part I of its guidance. in chapter 3, in respect of monitoring effectiveness of AML controls, to clarify that this includes group entities...
FCA cancels SPI registration for failure to register for AML supervision
The FCA has published a Decision Notice cancelling the registration of a small payment institution which had been registered with it for 5 years but, despite repeated warnings, had not registered with the HMRC for AML...
HMRC updates AML fees
HMRC is increasing its AML supervisory fees from 1 December. Following feedback that its initially proposed increases were too much, it has reduced the amount of some increases. The new fees will be: £500 for the fit...
FCA finds poor practices in financial crime risk assessment controls
The FCA has published the findings from its multi-firm review of a range of firms’ business wide and customer risk assessment processes. Key findings included: while most firms have a BWRA, not many were...
Treasury consults on FCA AML powers
Treasury is consulting on the key duties, powers and accountability mechanisms that the FCA will need to take over as AML supervisor of law firms, accountants and trust and company service providers. In the main, the...
Treasury responds to criticism over delays in designating critical third parties.. and more
At the House of Commons Treasury Committee meeting, Economic Secretary Lucy Rigby confirmed that critical third parties will be designated by this time next year – although this was couched with caveats that the...
Government publishes webpage with case studies on sanctions enforcement actions
The Government has published a webpage collating case studies and key lessons from sanctions enforcement actions taken by UK enforcement bodies. The page lists published monetary penalties, prosecution outcomes and...
HMRC adds TBML handbook to help site
HMRC has added a new handbook to its resources, to help firms identify trade-based money laundering and how to tackle it. The guide includes information on: common techniques; the legal framework; examples and case...
FATF plenary results
At the FATF plenary sessions from 22-24 October, it: removed Burkina Faso, Mozambique, Nigeria and South Africa from the list of jurisdictions subject to increased monitoring; adopted the first two assessments in the...
OFSI reminds firms of frozen assets reporting deadline
As part of its annual frozen assets review, the Office of Financial Sanctions Implementation (OFSI) has reminded firms that they will need to submit a report by 30 November 2025 if they hold or control funs or economic...
Treasury confirms FCA to take over AML supervision responsibility for all professional services
HM Treasury has announced reforms to anti-money laundering and terrorism financing supervision, granting the FCA responsibility for all AML/CTF supervision of professional services firms currently supervised by HMRC or...
FCA highlights widespread non-compliance in financial crime controls at corporate finance firms
The FCA has set out findings from its survey on financial crime controls in corporate finance firms. The review focussed on the 300 plus firms which are currently not required to submit financial crime data regulatory...
FCA publishes multi-firm review on combatting romance fraud
The FCA has published a multi-firm review on combatting romance fraud, setting out key findings on how firms detect and prevent this type of financial crime. Key findings included: Intervention and prevent are made...
Government publishes guidance on preparing for single UK sanctions list
The FCDO, HM Treasury and OFSI have launched guidance on the publication of a single sanctions list on 28 January 2026. Currently, UK designations are set out in 2 lists: the UK Sanctions List and the OFSI Consolidated...
PSR reflects on APP reimbursement impact one year on
One year after its implementation on 7 October 2024, the PSR has reflected on the impact of the APP reimbursement requirement. The latest figures show that in the first nine months following implementation: £112m was...
Government publishes guidance on ECCTA 2023 information sharing measures
The Government has published guidance on the information sharing measures under ECCTA 2023. The guidance sets out: The policy intent of the measures – namely the disapplication of confidentiality and civil...
G7 cyber experts publish group statement on AI and cybersecurity
The G7 Cyber Expert Group (CEG) has published a statement on AI and cybersecurity, outlining the rapid evolution of AI technologies and encouraging jurisdictions to monitor developments, promote public-private-academic...
FCDO publishes sanctions guidance
The Foreign, Commonwealth & Development Office (FCDO) has published a starter guide to UK sanctions and guidance on how to report a suspected sanctions breach. The starter guide is aimed at helping businesses and...
FCA speaks on market confidence
Therese Chambers of the FCA has spoken on how tackling financial crime can lead to increased confidence in the UK financial services marketplace. She quoted the FCA statistic of the number of UK consumers who prefer to...
FCA speaks on financial crime enforcement
Steve Smart of the FCA has spoken on the importance of detecting and disrupting harm caused by financial crime. He noted: that statistics show that those who fall victim to financial crime can lose confidence in the...
Court strikes out claim of CRM and Principle breach by retrieving bank
In the case of Dawn Barclay-Ross v Starling Bank Limited, the claimant claimed that, as a victim of APP fraud, she paid £120,000 from her Starling bank accounts. She sought to recover the amount she had paid, and other...
Finfluencers plead not guilty on illegal FX promotions charges
Three ‘finfluencers’ have appeared before Westminster Magistrates’ Court charged with offences relating to illegal promotions on social media posts. Charles Hunter, Kayan Kalipha and Luke Desmaris are...
OFSI issues sanctions breach report
OFSI has published a report on a breach of the Counter-Terrorism sanctions by Vanquis Bank. Delays in the bank’s processes for restricting account access meant that a Designated Person had full access to funds in...
Wolfsberg Group publishes fiat-backed issuer account provision guidance
The Wolfsberg Group has published its guidance for firms on providing bank account services for fiat-backed stablecoin issuers. In principle, the Group thinks that most of the same financial crime risk management...
Market Watch looks at corporate finance systems and controls
The latest edition of Market Watch contains the FCA’s observations on the systems and controls corporate finance firms have in place for handling inside information about their corporate clients. It has identified...
Home Office updates on Economic Crime Plan 2
The Home Office has published an outcomes progress report on the Economic Crime Plan 2, which was originally published in March 2023. It highlights: increases in both prosecutions and convictions for both principal and...
Treasury consults on MLR amendments
HM Treasury is consulting on the promised amendments to the MLRs. It has published the draft amending regulations for comment by 30 September. As Treasury noted in its feedback to its consultation on the need for...
FTP fraud offence takes effect
The Home Office has heralded the effective date of the failure to prevent fraud offence. It said the offence is intended to encourage organisations to build anti-fraud cultures in the same way the Bribery Act has helped...
Innovate Finance writes to Home Office on digital ID
Innovate Finance has published its submission to the Home Affairs Committee pointing out the benefits of Digital ID for combatting financial crime, streamlining services and fostering innovation. The submission looks at...
Wolfsberg Group reports on suspicious activity monitoring
The Wolfsberg Group has published its second statement on effective monitoring for suspicious activity. It has looked at how financial institutions are moving beyond traditional transaction monitoring and has now set...
Ready, set, go! Compulsory identity verification to begin from 18 November 2025
Companies House has confirmed that compulsory identity verification (IDV) will begin from 18 November 2025. IDV will become a compulsory part of the incorporation process, new director appointments and registration of...
Ella MarshSFO and CPS update prosecutor guidance in time for FTP fraud
The SFO and CPS have published joint updated guidance for prosecutors on dealing with corporate prosecutions, particularly with the failure to prevent fraud offence – which takes effect on 1 September – in mind. The...
“Associate” appeal in sanctions designation case refused
The wife of an individual designated under the sanctions regime has challenged her designation as a person “associated” with him. So far, she has challenged the designation at administrative review and then...
FCA publishes cyber resilience insights
The FCA has published some thoughts on good and poor practice arising from discussions with the Cyber Coordination Group during 2024. Key topics were: the reconnection framework and third party management: firms are...
Home office updates on POCA reporting exemptions
The Home Office has updated its guidance on the exemptions for the principal money laundering offences under POCA that mean those within the scope of them do not have to make a DAML SAR to proceed with a transaction...
NECC annual report
The National Economic Crime Centre‘s annual report for 2024-5 highlights work done : to combat fraud, including working with international partners; to fight illicit finance, including with significantly enhanced...
Regulators identify 5 live “wider implications” issues
The latest log of wider implications issues that potentially affect large numbers of consumers, where there could be significant redress or where there is a risk of business failure identifies 5 recent, new and ongoing...
FCA revokes ban after Supreme Court IBOR ruling
Following the Supreme Court ruling that quashed the convictions of Carlo Palombo and Tom Hayes the FCA has revoked Mr Palombo’s ban and ending its action against Mr Hayes, which he had referred to the Upper...
FCA appoints interim FOS chair
The FCA has appointed Liam Coleman as the interim chair of the FOS. His role will begin on 10 October 2025. Coleman has extensive financial services experience, including at the Co-Operative Bank, RBS and Nationwide...
Former deputy CEO banned for misleading FCA
Jean-Noel Alba, former deputy CEO of asset manager H2O AM has been fined �1m and banned from the financial services industry for deliberately misleading the FCA.
The firm had failed to carry out proper due diligence on investments between 2015 and 2019. During the FCA’s investigation, Mr Alba provided false and misleading statements and documentation. He also asked junior colleagues to create minutes where formal meetings had occurred, and provided due diligence materials, including investment research, which he claimed were produced at the time, but had in fact been created years after the investments were made.
Supreme Court quashes IBOR convictions
The SFO will not be seeking a retrial of 2 individuals it had started to investigate 13 years ago and who have now had their convictions quashed by the Supreme Court. The 2 traders had been accused of conspiring with...
Treasury consults on OFSI enforcement
HM Treasury is consulting on enhancing the effectiveness of the OFSI enforcement process. It is proposing: changes to the public case assessment guidance; discounts for voluntary disclosure and cooperation; a settlement...
Market Watch focuses on transaction reporting
The latest edition of Market Watch looks at recent FCA experience from supervising the UK MiFID transaction reporting regime. It is disappointed that it sees “persistent inefficiencies” from firms who have...
OFSI finds high risks associated with sanctions compliance in cryptoassets sector
OFSI has published a report setting out its threat assessment relating to sanctions compliance in the cryptoassets sector. Key takeaways included that it is: almost certain that cryptoasset firms have under-reported...
NCA and FCA highlight 9 economic crime priorities for regulated sector
The NCA and FCA have set out their 9 priorities for tackling economic crime in the regulated sector. The publication follows the 2025 NRA, and the NCA and FCA say there will be further guidance to help firms interpret...
POCA threshold amount increase
The threshold amounts under which banks and payment firms can carry out transactions where they suspect money laundering without needing a defence under POCA has been increased from £1,000 to £3,000 with effect from 31...
National Risk Assessment highlights increased risk arising from adoption of financial technologies
The Home Office has published the fourth National Risk Assessment, setting out the key money laundering and terrorist financing risks for the UK. The NRA identifies the following key risk areas: fraud; sanctions...
OFSI launches online reporting and licencing forms
OFSI has launched online forms for submitting licence applications, reporting suspected breaches, and other key reporting such as on frozen assets. The forms will operate alongside existing processes during a transition...
HM Treasury sets out improvements to MLRs
HM Treasury has reviewed the responses to its consultation on improvement the effectiveness of the MLRs, and has published a response setting out key areas where it intends to make changes. The consultation covered four...
FCA fines for financial crime failings
The FCA has levied another fine on a bank for financial crime risk management failings. This fine was on Barclays Bank UK PLC and Barclays Bank PLC and related to 2 clients: in one case, failure to check that the bank...
PSR publishes annual report
The PSR annual report focuses on:
that 99% of FPS transactions are now within Confirmation of Payee;
the APP fraud reimbursement reforms;
driving forward open banking; and
reaching milestones on card fee reviews.
FCA annual report highlights key stats
The FCA’s annual report highlights its work in several areas, including: to tackle financial crime and unauthorised financial services, it suspended, removed or blocked over 1,600 websites in 2024 – also working with...
Treasury updates AML advisory
HM Treasury has updated its AML advisory notice in respect of high risk third countries, following the latest FATF meeting. The changes to the list took effect from the date FATF published it.
BoE sets out thematic findings from 2024 Cyber Stress Test
The BoE has published a report setting out its thematic findings from the 2024 Cyber Stress Test, a voluntary exercise which involved providers and users of wholesale services to model the impact of a suspected cyber attack affecting transaction settlement.
The stress test used three variations of the scenario: a suspected cyber attack; a confirmed cyber attack; and a longer cyber attack.
Key findings included:
Financial stability decisions�– while participants had mature scenario modelling and response capabilities, they lacked a comprehensive understanding of the FPC’s Impact Tolerance and how potential impacts could lead to financial instability.��Firms are encouraged to consider actions to protect financial stability and manage systemic risk from operational disruptions;
Financial stability mitigation
Operational mitigation – some participants had not tested all available workarounds for processing payments, highlighting the need for firms to collaborate with FMIs to ensure awareness and adoption of mitigation options;
Confidence mitigation – participants demonstrated good understanding of the Sector Response Framework (SRF) processes.��However, further work is needed to improve awareness of operational resilience contingency procedures among customer relationship managers and incident responders;
Financial mitigation -while capital is a fungible mitigant to losses, it does not mitigate operational disruption impacts. Service providers needed a better understanding of customer firms’ funding positions to meet liquidity needs during longer incidents;
Disconnection and reconnection – firms’ decisions about disconnecting from critical systems affect their ability to mitigate financial stability impacts.��It is important for firms to understand disconnection and reconnection options, align them with risk appetites, and reflect potential financial stability impacts in their playbooks.��The Cross Market Operational Resilience Group (CMORG) is working on defining best practice reconnection processes.
FCA fines Monzo for financial crime control failings
The FCA has fined Monzo £21m for failings in its financial crime systems and controls. The failings became apparent as Monzo’s customer base and its product offering grew rapidly, and its financial crime prevention...
FCA updates PEP guidance
The FCA has published its updated finalised guidance on the treatment of PEPs for AML purposes. The update follows its 2024 consultation, which noted that the old 2017 guidance was still basically suitable, but...
Individuals sentenced to combined 12 years imprisonment for crypto fraud
Raymondip Bedi and Patrick Mavanga have been sentenced to a combined 12 years imprisonment for their involvement in a �1.5m crypto fraud conducted between February 2017 and June 2019, involving them cold calling victims to sell them fake investments in crypto.
Bedi was sentenced to 5 years and 4 months, while Mavanga received 6 years and 6 months.
The sentencing follows convictions achieved by the FCA late in 2024. Confiscation proceedings aiming to recover the proceeds from the fraud are ongoing.
APPG on Fair Banking publishes APP report
The All Party Parliamentary Group on Fair Banking has published its “blueprint” on how to beat APP fraud. The report looks at how the UK is responding to threats and the early impact of the mandatory reimbursement...
FCDO publishes sanctions guidance for non-UK businesses
The Foreign, Commonwealth and Development Office (FCDO) has published guidance on UK sanctions for non-UK businesses. The guidance concerns sanctions targetting Russia, and aims to assist businesses in third countries...
FCA secures guilty plea in fraud case
The FCA has secured a guilty plea from John Burford in a £1m investment fraud case. As sole director of Financial Trading Strategies Limited, Mr Burford had promoted a paid-for subscription service offering daily trade...
FCA secures insider dealing and money laundering convictions
The FCA has secured convictions against Redinel Korfuzi and his sister Oerta Korfuzi for insider dealing and money laundering offences from which they had earned over �1m.
Redinel Korfuzi was a research analyst at an asset management firm, and between December 2019 and March 2021 conspired with his sister to use confidential price-sensitive information to deal in the shares of at least 13 publicly traded companies ahead of market announcements. The relevant trades were executed using contracts for difference (CFDs), and were detected by the FCA’s market monitoring system, despite arrangements which were designed to obfuscate Korfuzi’s involvement.
During the relevant period, the Korfuzis had also received cash derived from the proceeds of crime totalling �198,210. The FCA plans to apply for confiscation orders in order to recover these monies.
New guidance on quantum-safe cryptographic practices
The Cross Market Operational Resilience Group has published guidance to help the financial sector transition towards quantum-safe cryptographic practices as institutions move to post-quantum cryptography. PQC refers to...
Caroline ChurchillInnovate Finance queries FCA proposals on contactless limits
Innovate Finance has responded to the FCA call for input on contactless limits. It queries whether the proposals really do align with economic growth objectives. It cites the crucial need for regulatory focus on SCA and...
OFSI publishes threat dashboard for art and high value goods sectors
OFSI has published a new set of� threat assessments �to help art market participants and high value goods dealers comply with financial sanctions requirements.
The guidance notes that there are numerous designated persons across many sanctions regimes who are high-net-worth individuals with footprints and assets in the UK, who may seek to use these sectors to buy and sell relevant assets – meaning that businesses who deal with them risk breaching sanctions restrictions if they are not alive to the risks and apply for licences where needed.
Alongside other entities within the AML regulated sector, these businesses are additionally subject to OFSI reporting requirements.
On the whole, OFSI says it is highly likely that high value goods owned by designated persons in the UK have not been reported to OFSI and it is likely that Russian designated persons and their enablers have dealt with goods in the UK in breach of asset freezes. It is also concerned that it has received a high number of suspected breach reports about high value goods submitted by other firms, such as financial services providers and legal firms – which it says emphasises that HVG dealers need to ensure they comply with their new reporting obligations now.
The guidance also reminds firms that where they are reporting to OFSI they should also consider whether they need to make a SAR to the NCA – again, it believes the sector is under-reporting based on the number of registrations of firms in the sector on the NCA SAR Portal
Finally, the guidance sets out some examples of what should be clear red flags of potential sanctions (and AML) issues and provides a couple of case studies, including a recent CPS report of an art dealer jailed for failing to report under Terrorism Act obligations his dealings with a suspected terrorist, who was also sanctioned by the US Government.
FATF updates on high risk jurisdictions and cross-border payments
At the joint FATF-MONEYVAL plenary meeting last week: the list of jurisdictions subject to increased monitoring was updated so that Bolivia and the BVI were added, and Croatia, Mali and Tanzania removed; the meeting...
SFO gets investment for economic crime
The Government will give the SFO more funding as part of the Spending Review. The SFO will use it to strengthen its intelligence and information gathering work in relation to economic crime.
UK Finance says over £1bn stolen in 2024
UK Finance has published its annual fraud report for 2024. Headlines include: its members reported £1.17bn stolen through authorised and unauthorised fraud, roughly the same as the previous year; 3.13m confirmed cases...
FCA bans former Credit Suisse VP
The FCA has banned former Credit Suisse Vice President Detelina Subeva for lacking integrity. This is the third ban on former Credit Suisse staff following their roles in conspiracy to commit money laundering, which...
PSR consolidates APP reimbursement publications
The PSR has published a consolidated policy statement comprising all previous publications on the APP scam reimbursement requirement, sot that firms will now have a single point of reference. The document also...
FCA publishes last quarter operating metrics
The FCA’s operating metrics from the quarter to end March 2025 shows 13 green, 3 amber and just one red – which was due to just one application (an MLD5 registration) being determined after the statutory deadline. 348...
PSR reflects on APP reimbursement story so far
The PSR has looked back at the 7 months since the APP scam reimbursement requirement went live. It is pleased with the data it has seen and what it has heard from firms and is generally seeing positive results. It is...
Transparency International criticises overseas territory progress
Transparency International has criticised Anguilla, Bermuda, the BVI and the Turks and Caicos Islands for continuing to miss deadlines for opening up their corporate registers. As of 1 May 2025, out of the 5 Overseas...
Committee hears evidence on finfluencers
On 30 April 2025, the Treasury Committee heard evidence from the FCA as part of an inquiry on finfluencers. Steve Smart, Joint Executive Director for Enforcement and Market Oversight, and Lucy Casteldine, Director of...
UK crypto business shut down following Insolvency Service investigation
BTCMining Limited – a cryptoasset business registered in the UK – has been shut down following an Insolvency Service investigation and a High Court winding up hearing on 29 April 2025. The Insolvency Service...
FCA speaks on market abuse
Therese Chambers, FCA joint executive director of enforcement and market oversight – has delivered a speech on the FCA’s agenda for combatting market abuse, at the City and Financial Global Market Abuse and...
SFO gives corporate co-operation guidance
The SFO has published guidance for corporates setting out the factors it considers when deciding whether to charge corporates with criminal offences or invite them to negotiate a deferred prosecution. The key message is...
High Court finds EMI was “on enquiry” of potential fraud and breached Quincecare duty
The High Court has supported victims of an APP scam who brought a “derivative” action for reimbursement against a PSP in place of the PSP’s customer company, which the victims had been duped into...
Committee inquiry to hear evidence from FCA on finfluencers
The Treasury Committee will hear evidence from the FCA as part of an inquiry on finfluencers at a meeting on 30 April 2025. Evidence will be heard from Steve Smart, Joint Executive Director for Enforcement and Market...
PSR explores changes in the payments landscape
The PSR has considered changes in the payments landscape from consumer, merchant and industry perspectives. For consumers, the PSR notes growth in digital payments and digital wallets technology. Cards remain the most...
UK insurance firm charged with “failure to prevent” offence
The SFO has charged United Insurance Brokers Limited with failing to prevent its US based intermediaries from bribing Ecuadorian state officials. The alleged activities happened between 2013 and 2016 and relate to...
FCA speaks on delivering enforcement priorities in collaboration with the US
Therese Chambers – FCA joint executive director of enforcement and market oversight – has delivered a speech on delivering enforcement priorities at the Spring Conference of NYU’s Program on Corporate...
OFSI publishes property services threat assessment
OFSI has published its latest “threat assessment” for the property and related services sector. The assessment, an update of the 2022 assessment, is relevant to all firms and sole practitioners involved in...
FCA updates Regulatory Initiatives Grid
The updated Regulatory Initiatives Grid highlights many initiatives for various regulators relevant to the financial markets, including: during 2025: further action plan on FCA requirements in light of Consumer Duty...
Companies House changes – get ready for identity verification
We’ve written this article on the identity verification reforms being introduced under the Economic Crime and Corporate Transparency Act 2023.
PSR defers APP claims management system consultation
The PSR had planned to consult in April 2025 on adopting Reporting Standard B and whether to put in place regulatory requirements for Pay.UK’s reimbursement claims management system. Having considered stakeholder...
FCA publishes work programme 2025-6
The FCA has published its work programme for 2025-26, which builds on the 4 priority areas in its 5 year plan. Specific initiatives additional to those set out in the 5 year plan (which we summarised in this article)...
OFSI publishes financial sanctions guidance for insolvency practitioners
The Office of Financial Sanctions Implementation (OFSI) has published guidance on financial sanctions aimed at insolvency practitioners and firms. The publication comes after insolvency practitioners have been added to...
FCA updates cash-based money laundering webpage
The FCA has updated its webpage on cash-based money laundering, which sets out the regulator’s recent work on reducing money laundering through cash deposits via the Post Office, and its expectations of...