An interesting title for this story which needs some analysis. Corrupt foreign officials have always found ways and means to launder their ill-gotten funds and assets in jurisdictions where they feel more secure. Blaming all Family Offices is like blaming all banks for the events at Denskebank’s Latvia branch. The real story here is that the NCA finally has new tools to prosecute Politically Exposed Persons (PEPs) and their related parties. The Unexplained Wealth Order enacted as part of the Criminal Finance Act (2017) is aimed at PEPs and their related parties who are unable to provide evidence to support their assets or spending habits. All parties involved in the transactions noted in this article were required by their respective regulators to perform Enhanced Due Diligence on these clients as they were clearly high risk PEPs from countries deemed to be high risk from an AML perspective. This would have required them to assess not just the source of funds but also source of wealth. Had this been done properly, the clients would not have been on-boarded in the first place and / or the funds transfer should have been reported to the FCA as a Suspicious Transaction. Look out for more similar cases in the coming months!