Barclays
AML & Financial Crime Prevention Training

Lesson 1

Introduction to AML & Financial Crime

3 min 20 sec 15 scenes
What money laundering is
How it works through three stages
Why it matters at Barclays

The Global Financial Threat

United Kingdom
Hundreds of billions laundered annually
Definition

Money Laundering

The process of making illegally obtained money appear legitimate — transforming the proceeds of drug trafficking, fraud, and corruption into funds that can be spent without suspicion.

Drug Trafficking Fraud Corruption

Global Scale

2-5%
of Global GDP
USD 2T
Laundered Annually

Source: United Nations Office on Drugs and Crime

The UK Picture

GBP 10B
Through Mule Accounts / Year
37,000
Accounts Flagged (2023)
Placement
Layering
Integration

Getting Dirty Cash Into the System

The most vulnerable stage for criminals — where illicit cash first touches the banking system.

Placement
Layering
Integration

Smurfing

Multiple small deposits below GBP 10,000 across branches

Cash Businesses

Restaurants, car washes, nail salons co-mingling illicit cash

Money Mules

Recruited via social media — 37,000 flagged UK accounts

Branch: Manchester Central GBP 9,500 Below threshold
Branch: Leeds Park Row GBP 8,200 Below threshold
Branch: Birmingham New St GBP 7,800 Below threshold
Placement
Layering
Integration

Creating a Maze of Transactions

Shell Companies

No real business — just moving money through corporate layers

Wire Transfers

Multi-country hops crossing regulatory boundaries

Crypto Mixing

Tumblers pool and redistribute to obscure the trail

5-6
Countries in Hours

By the time it arrives, the trail has gone cold.

Placement
Layering
Integration

Looking Legitimate

UK Property

GBP 10 billion laundered through real estate each year

Luxury Goods

Art, jewellery, vehicles — hard to trace provenance

Business Investment

Generating real revenue that obscures illicit origins

Enterprise Risk Management Framework

Barclays Bank PLC — Effective 1 January 2025
ERMF
Credit Risk
Market Risk
Treasury & Capital
Climate Risk
Operational Risk
Model Risk
Compliance Risk
Financial Crime ELEVATED
Reputation Risk
Legal Risk
January 2025 — Elevated to Principal Risk

Stunt & Co

Case Reference — FCA Enforcement
HIGH RISK
GBP 46.8M
From Fowler Oldfield
5 Years
Without Proper Review
Convicted
Gold Dealer — ML
Police warnings & raids → 5-year delay before relationship review
FCA Enforcement Notice
GBP 42M

International headlines. Damaged trust.

Principle 2 Breach
Principle 3 Breach

The consequences of poor financial crime controls are very real — they allow criminals to launder the proceeds of their crimes.

Therese Chambers
FCA Joint Executive Director, Enforcement

Your Responsibility

Recognise

Know the red flags. Understand the stages. Spot suspicious activity.

Report

File SARs through proper channels. Never tip off.

Protect

Safeguard Barclays, our clients, and the financial system.

AML compliance is every employee's personal responsibility.

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