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1. Introduction
Jersey has long been recognized as a safe haven for white-collar and organized criminals who intend to launder money through its financial institutions (Bedell, 2014; Armitage, 2015). The nature of the financial sector business conducted in or from Jersey creates a material vulnerability to being used in the layering and integration stages of money laundering and terrorist financing schemes (International Monetary Fund (IMF), 2009, p. 16). In a recent press release, the Head of the Joint Financial Crimes Unit (JFCU) in Jersey, Dave Burmingham, noted that his department was currently investigating money laundering schemes consisting of multi-million pounds and involving very complex structures from all around the world across most of the continents (Jersey Evening Post, 2015, para. 7). Burmingham went on to reason that because of Jersey’s close proximity to Europe and London, it has become an attractive location for money launderers and possibly those financing terrorism (para. 9). Jersey's strategic location has made it one of the preferred locations to conceal corrupt property purchases and proceeds of (mainly) foreign fraud and corruption (IMF, 2009, p. 16).
According to estimates, millions of dollars are laundered into Jersey’s financial sector every year (Jordan et al., 2011). Two known money laundering cases in Jersey highlight the point. The first case involves two brothers, who were able to wash $7m of Russian funds through the Jersey real estate sector by infiltrating and circumventing the internal control system of a local bank. In the second, and arguably one of Jersey’s most notorious and largest cases, Raj Arjandas Bhojwani laundered £28m through Jersey’s branch of the Bank of India (Pidd, 2011). It is alleged that the money was laundered through a business deal with the late Nigerian military dictator General Sani Abacha to provide overpriced trucks for the Nigerian army. These examples leave question marks on the fitness and propriety of compliance officers to serve as gatekeepers to the anti-money laundering (AML) regimes of financial institutions in Jersey.
The purpose of this paper, then, is to explore the dynamic complexities experienced by compliance officers in Jersey to detect and report suspicious money laundering activities. The paper explores the factors that compliance officers take into consideration when submitting a Suspicious Activity Report (SAR)[1] and draws on the...