Lessons learnt

Details of the lessons learnt based on the experience of the case team.

Areas where the case team might either change or adjust their strategy for future money laundering investigations:

Consider different options and approaches in the intelligence gathering phase

In the initial stages of operation A, surveillance capability was limited. Therefore, the case team had to use alternative methods, such as the use of account monitoring orders to monitor cash deposits arriving into the bank accounts, which used in conjunction with the CCTV obtained from the financial institution, not only meant the case team were able to widen the scope of their investigation, but also provided evidence at the trial stage which had a huge impact.

Use as many resources as is appropriate

This would include ensuring having forensic practitioners either onsite or contactable during an intervention to maximise the potential evidence collection. Onboarding experts such as a money laundering expert, the Companies House liaison officer and insolvency service officer from an early stage was also beneficial to building a complete picture in operation A. One of the roles of an expert is to explain complex matters in a more simplistic manner, so the more experts on the case, the less explaining there might be for the case team.

Use of the Egmont Group

In operation A the case team experienced difficulties in obtaining evidence overseas, however they recognised there were alternative options including the use of the Egmont Group. The case team also used HMRC’s fiscal crime liaison officer network who were able to confirm the request from the UKCA had not been received but were also able to provide intelligence on the subjects under investigation. There is a global outreach of illicit finance experts who can be reached via HMRC, National Crime Agency or the Foreign, Commonwealth and Development Office to help with overseas enquiries.

Early investigative advice

It is recommended to set out a detailed investigation strategy as well as obtaining early investigative advice from the CPS to agree the strategy from the outset of the investigation.

Sharing and learning

The case team reached out to the HMRC trade-based money laundering threats team having received a presentation on TBML methods and typologies. The presentation resonated with the case team who recognised numerous TBML indicators in operation A and felt that through sharing their experiences, learning can be shared.