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Image credit: Picture courtesy of Europol

Thinking like a poacher is critical to managing an effective and meaningful risk assessment process and countering the risk of supporting their illicit activities.

Well-resourced and committed criminal financiers and terrorist financiers will be aware that the authorities are enhancing mainstream regulated sector controls, and will be looking for alternative means of moving 'value'.

Good work by Europol and their partners in identifying yet another 'new' and emerging threat, although I suspect it is not so new at all! If something has a value, it is likely to be attractive and support the ‘plausibility’ statement that is provided to explain the cross border movement of value between criminally collusive partners.