Stopping illicit financial flows: What can be done? 
(And can we avoid throwing the baby out with the bathwater)? 

Held on Monday, January 25, 2016

With support from Eversheds


  • Tom Keatinge (director of the Centre for Financial Crime & Security Studies, RUSI)

  • Commander Chris Greany (City of London Police)

  • Donald Toon (director, Economic Crime Command, National Crime Agency)

  • Stephen Lock (head of group financial crime prevention, Old Mutual)

  • Geoff Cook (CEO, Jersey Finance)

  • Zia Ullah (partner, Eversheds)


Jane Fuller, co-director of the CSFI, talks to Tom Keatinge (RUSI) and Nigel Kirby (National Crime Agency) following the Centre's January 25 round-table on countering illicit financial flows.



Finance is global; money moves from country to country, with scant regard to borders (or legal jurisdictions). Our economy is also, largely, global; the days of autarchy are long gone, and no one wants them back. Unfortunately, however, financial crime and (as we are increasingly aware) terrorism are also international – and they don’t pay any regard to national border control.

So, how do the authorities cope? And is it even remotely realistic to hope that we in the UK (and more specifically in the City) can develop an effective strategy to counter illicit financial flows without choking off the legal flows on which our prosperity depends? Anyone (and this probably means almost all of you) who has fumed at the apparent imbecility of KYC here in the UK, or (for American persons) who has been forced to strip down to his or her financial underwear by FATCA, knows the problem: the rules are irritating, intrusive and (often) wrong-headed. But do they work? And are there alternatives that might address the problem (which we all accept) more effectively.

That is an enormously important issue to kick off the New Year with. I am, therefore, delighted that we have been able to put together an extremely distinguished panel.

Laying out the scope and scale of the problem is Tom Keatinge, director of the Centre for Financial Crime & Security Studies at the Royal United Services Institute in London. His work has focused on the funding of terrorist/extremist groups and the use of financial intelligence as a security tool. Prior to joining RUSI, he spent 20 years in investment banking at JP Morgan, where he was an MD in the financial institutions group.

Laying out what the authorities are doing are two ‘top-cops’:

  • Chris Greany joined the City of London Police from the Metropolitan Police Service (MPS) in September 2015 and is the National Coordinator for Economic Crime. From 2008 to 2011, he was head of counter-terrorism for the CoL Police.

  • Nigel Kirby is Deputy Director of the Economic Crime Command in the National Crime Agency, responsible for leading the UK’s response to money laundering, corruption, sanctions, IP crime etc. 

But they won’t get things all their own way. Batting for the City will be Stephen Lock, Head of Group Financial Crime Prevention at Old Mutual – who has had to implement and monitor all the rules and regulations from Basel, Brussels, DC, wherever. He has oversight of AML, sanctions, anti-bribery (and soon to be tax evasion) compliance across a broadly based international financial services Group (with much of its business in Africa but listed in the UK). In addition, we have an old friend, Geoff Cook, chief executive of Jersey Finance since 2007. He is responsible for promoting Jersey as a clean, FATCA-compliant financial centre in the competitive world of offshore finance.

And then there is Zia Ullah – a partner at our hosts, Eversheds, who specializes in financial crime and regulatory compliance issues, with a special focus on sanctions, AML and anti-bribery activities. He was previously the Global Head of Sanctions at Barclays.

In other words, a stellar team.