（前言：這篇文章寫於俄羅斯出兵烏克蘭東部前夕。本來打算封筆，但是見到上佳題材忍不住手，也希望能夠為支持香港的烏克蘭手足出一點力。）
這篇文章所用的材料來自一位外國金融罪案專家的文章，作者：Graham Barrow，原文連結見＜參考資料＞部份。他曾任職匯豐 (HSBC) 和德意志銀行 (Deutsche Bank)，所寫的文章令監管機構採取行動，即是有份量。
他研究在英國註冊的公司資料，留意到一個現象：2021 年在英國註冊並且由中國人名字出任董事的空殼公司數量明顯上升，是否跟中國的金融監管機構打擊虛擬貨幣交易活動以及加強反洗黑錢 (Anti money laundering, AML) 法規有關，有待查證。他筆下的另一個古怪現象：有人動用了一批來自中國山東省某村的居民的個人資料在英國註冊開設公司，兩日之內密集式地開設了七間公司。他也見過有越南人的個人資料被盜用，在英國註冊開設多間公司，而受害人來自同一條村或同一地區。那些個人資料是怎樣收集得來的？是否有地方官員貪污或失職，還是電腦黑客透過資訊科技保安漏洞取得，然後透過互聯網出售或轉移，自己想。
壞人的思路：現實世界的司法制度以國界為基礎，把個人資料轉移到另一個國家或司法管轄區 (Jurisdiction)，用來開設空殼公司或網上銀行賬戶洗黑錢，就算日後受害人（透過傳媒報導）發現個人資料被盜用，要追究責任也很困難。此外，還要花費不少時間與功夫去跟另一個國家的官僚周旋，才能還自己一個清白，洗脫跟犯罪集團合作的嫌疑，對不對？如果受害人來自窮困的第三世界，教育水平低或不懂外語，又或者是政治上處於弱勢的少數民族，難度就更高，對不對？這種玩法擺明是鑽空子，背後是否有跨國犯罪集團在操控，自己想。
不止 Graham Barrow 留意到這種情況，英國傳媒也發現有中國人盜用英國人的地址開設空殼公司。情況很誇張，一個地址被用來開設多間公司，傳媒估計每日最少有幾十間這種公司在英國註冊。真業主（小市民或小商戶）收到大量的信件才發現自己的地址被盜用，想移除公司註冊處的紀錄？要經過繁複的手續，即是浪費時間跟政府公務員周旋，於是向傳媒投訴兼求助。然後傳媒進行調查報導 (Investigative journalism)，揭發跨國犯罪集團密集式地開設空殼公司的古怪現象，估計那些公司稍後會被中國人用來走資，又或者開設網上銀行賬戶洗黑錢。有理由相信，被傳媒發現的個案不過是冰山一角，（中國人）在英國註冊的空殼公司總數也許非常驚人，事件被外國傳媒形容為 Industrial scale money laundering。
英國傳媒的看法：中國人很可能繼俄羅斯人之後，利用英國的金融中心地位洗黑錢。英國的政府部門已經準備收緊移民政策及加強相關的反洗黑錢法規。今日的西方世界視俄羅斯和中國為敵人，有這種想法，不難理解（提示：英國和美國因應俄羅斯入侵烏克蘭，準備在金融層面對俄羅斯實施制裁）。如果屬實，那些來自俄羅斯和中國的黑錢，稍後是否又要轉移到另一個地方（傳統的避稅天堂還是網上的虛擬世界）？即是（洗黑錢的）老鼠繼續逃避御貓（監管機構）的追捕？貓捉老鼠（提示：Tom & Jerry），沒完沒了，就是這樣。
香港人的角度：這種個人資料被跨國轉移，然後在另一個司法管轄區 (Jurisdiction) 開設空殼公司或網上銀行賬戶洗黑錢的玩法，跟香港在過去兩、三年間政治形勢急轉直下有沒有關係？壞人（走資或洗黑錢的大陸人）是否因為眼見香港的金融中心地位岌岌可危，早晚要放棄香港這個洗黑錢中心，於是超前部署或兩手準備，跑去英國開設一堆空殼公司或網上銀行賬戶，然後繼續玩下去？簡單地說：香港（就快）玩完，黑錢也移民，跟港人一樣去英國。對，壞人先知先覺，高手在民間。
異曲同工的玩法：你去見工，兇巴巴的港女 HR or agent 甚麼話也不說，就迫你填申請表，同時要脅你：如果填漏了任何一項，就無法進入下一輪的選拔賽！即是用不知真假的職位空缺跟求職者玩情緒勒索 (Emotional Blackmail)。遇上這種情況，聰明的你是否應該停一停，想一想，轉身走？解釋：部份（自稱獵頭族的）人事顧問公司其實是不斷更改名字和地址的艇仔（門面公司），所收集的個人資料（以及各種文件）稍後會分類打包出售，即是求職者被用來供養一條肉眼看不見的地下產業鏈。請參考這個博客內的另一篇文章「進階版」求職須知 (Part 5)，日期：2019 年 1 月 10 日。根據中文傳媒的報導，曾經有港人的個人資料被盜用，在中國大陸的銀行系統開設賬戶然後洗黑錢。那些個人資料是怎樣收集得來的？自己想。
插圖來源：www.fotosearch.com
YouTube 精選：
Matt Monro - 'From Russia With Love' (with lyrics) (2:35)
https://www.youtube.com/watch?v=YwLXDv6jXr4&feature=youtu.be
James Bond 電影主題曲。
Welcome to Russia - Family Guy - (4:02)
https://www.youtube.com/watch?v=nVfNiUtsfnU&feature=youtu.be
拿普京開玩笑的美國卡通。
Volodymyr Zelenskyy 2016 Playing Piano with Penis (5:55)
還是喜劇演員的烏克蘭總統用 J 彈鋼琴。
延伸閱讀／參考資料：
Graham Barrow
Director of The Dark Money Files Ltd
https://www.linkedin.com/in/greybrow53/
Graham Barrow - Here is a thing I found
Here is a thing I found. This chart shows all UK company incorporations for 2021 where the named director was Chinese, along with an arrow at the point that China banned the use of crypto transactions. Do you think they might be related?
Graham Barrow - On the road to Zhangzhuang（張庄村，地點接近京九線）
Summary: Here is the story of how one small village in the northeastern Chinese province of Shandong（山東）, managed to provide the directors for seven newly incorporated UK entities in the space of two days, a couple of weeks ago. It is almost unbelievable (and yet it is true). What do you think the chances are of seven companies, bearing similar names, with the same SIC codes and directors who all live in the same village in rural China, being incorporate to seven different addresses in the UK in the space of two days. Because I reckon they are slim.
Identifying patterns in Companies House data
Graham Barrow
2021-12-21
https://www.linkedin.com/pulse/identifying-patterns-companies-house-data-graham-barrow
Extract: As you will see from my example, this clearly showed that Vietnamese individuals incorporated three of those companies, using three different registered addresses. Not only that, but each incorporated with £50,000 of shares and all fell within a narrow range of ages.
This then prompted me to download all the companies registered to those three addresses since the start of December. As you can see, whilst there were companies other than those being registered by Vietnamese, they were in the minority (and I could have done this for a wider date range, but it yields an awful lot of results!) Not just that, but every single Vietnamese registration was for a company incorporating with £50,000 of capital and the overwhelming majority had directors born since 1990.
To be clear, I am not suggesting anything criminal is happening, but equally clearly, this is not just a random group of people, registering companies against the same Industry Classification for the same amount of capital, to one of three addresses. However, it is highly relevant to the risk you are taking on, to understand exactly what that relationship is.
Why kleptocrats and money launderers love Companies House
The financial expert Graham Barrow explains how Britain’s corporate register enables criminals to move funds without anyone noticing.
By Will Dunn
The New Statesman (Mar 22, 2022)
Extract: For more than two decades, a bank executive who ended up in a room with Graham Barrow knew that they were in serious trouble. With a warm smile and a quick sense of humour, Barrow is far from intimidating, but much of his career as an expert on financial crime, money laundering and compliance has been spent with people who have, as he politely puts it, found themselves in “regulatory distress”.
Perhaps surprisingly, he still gives bankers the benefit of the doubt. “I’ve never worked with any bank that I’ve thought was evil,” he says. The problem, for him, is inherent in the business model of financial services. “The issue, across the entirety of banking, is that the risk of laundering money is different from every other risk a financial institution faces.”
A bank that is lending money is taking on risk (of non-payment), in return for returns (from interest). A bank that checks where that money comes from is also taking on more risk (of having to turn away business), but it’s spending money to do so. “Banks make money from dealing with criminal funds,” Barrow says. “It is one of those risks that the more they do about it, the less they earn, and the more it costs them to do it.”
REVEALED: The flat above a West Country takeaway that is home to 761 Chinese firms - and fraudsters are suspected of registering more than 11,000 companies in the UK in the past year
By Michael Powell And Mark Hookham
Daily Mail (05 Feb 2022)
Extract: An astonishing 761 companies have been registered by Chinese companies in the past year at this modest flat above a takeaway shop in Somerset, a Mail on Sunday investigation has revealed. Chinese fraudsters are suspected of registering more than 11,000 new companies in the UK in the past year by exploiting a ‘soft touch’ system that lets anyone create a new business without proof of identity. Our investigation has found that Chinese nationals have been registering an average of more than 30 new companies every day over the past 12 months on the Government’s Companies House website.
Most of the firms are registered to only 18 addresses, including the flat above the Canton Chef takeaway in Weston-super-Mare, a derelict shop, a £1 million flat and houses on a surburban street in South London. Furious property owners – who have no link to the companies or their activities – usually discover their premises have been registered as the headquarters of a newly formed Chinese company only when a letter arrives from Companies House.
While it can take weeks of form filling to get the bogus company removed, it takes less than 15 minutes and costs just £12 to register the company and needs neither proof of address, passport nor driving licence. Billions of pounds has been laundered in Britain in recent years by Russian criminals, leading London to be dubbed Londongrad by fraud experts. Now there are fears that Chinese fraudsters are taking advantage of the lax system to launder money out of China to avoid high taxes and the communist regime’s currency control.
‘The soft-touch system for registering companies in the UK is a fraudster’s paradise,’ said Graham Barrow, a former investigator for HSBC and Deutsche Bank, who uncovered the scandal. Mr Barrow, who hosts The Dark Money Files podcast, added: ‘Once they have a UK company registered, these crooks will use it to get an online bank account that they can use to funnel money before anyone challenges the new company or Companies House finally gets round to striking it off.’
According to the National Crime Agency, these types of shell companies – which have no staff and do not trade but move assets on behalf of individuals or other businesses – are being used to launder £100 billion of stolen and illicit money through Britain each year.
People struggling to have their names and home addresses removed from bogus firms registered at Companies House by fraudsters
By Rachel Rickard Straus
Financial Mail (23 Oct 2021)
Extract: People are struggling to have their names and home addresses removed from bogus firms registered at Companies House by fraudsters. Experts warn that fake information posted on the official register of UK companies is leading to small firms being scammed out of thousands of pounds.
Last month, The Mail on Sunday reported that tens of thousands of people are unknowingly having firms set up in their name by fraudsters who shockingly use the details to take out loans or swindle consumers.
Despite promises by the Government to beef up its powers, Companies House is powerless to check the veracity of information supplied by those forming a new firm. As a result, its register is littered with false data. Since our report, we have been deluged with correspondence from victims and experts worried at the inability of Companies House to tackle this mountain of fraudulent information.
Retired chartered librarian William Clarke, 77, pleaded with Companies House to remove his home as the registered address of a firm he had never heard of. He says he was told by Companies House it would take 35 days for his address to be removed. 'Before that I had to prove I lived at my own address,' he says. 'But the people who fraudulently registered the firm at our address didn't need to provide any evidence.'
Whatever weapons we have against Russian dirty money, Companies House ain't one of them
Businesses are incorporated in the UK with blatantly false details, like the one claiming to have more share capital that the entire world's economic worth
By Andrew Penman
Mirror (24 Feb 2022)
Extract: What world are some government ministers living in? Earlier this month we had Business Secretary Kwasi Kwarteng downplaying fraud as not a “crime that people experience in their day-to-day lives”, despite the fact that you’re more likely to be a victim of fraud than any other crime. Now Transport Secretary Grant Shapps has declared on ITV's Peston show that Companies House and “our auditing system” has “some of the highest standards in the world”, capable of spotting Russian dirty money being laundered in the UK. Really? I doubt that even Companies House would claim to have some of the highest standards in the world – you only have to go on to its website to see the disclaimer that it “does not verify the accuracy of the information filed”.
We followed a crypto scam from the start. Why can’t the police?
Ali Hussain goes on the trail of the mystery man behind a series of scam firms that operate from one street in London
The Times (February 9, 2022)
Extract: A company called Cryptomeracoin suddenly becomes listed on Companies House, the UK registration service for businesses. It is spotted by Graham Barrow, an anti-fraud consultant.
The registered address of Cryptomeracoin is in Eaton Square, London, one of the most exclusive addresses in the UK, a stone’s throw from Buckingham Palace. Now there is a sense of urgency — the scammers are clearly getting ready to act. “The website is already up and running, ‘trading’ in Bitcoin,” Barrow tells the National Crime Agency (NCA), which is responsible for monitoring fraud.
So how would this scam work? We do not know for sure, but it is likely that anyone transferring money to cryptomeracoin.com would be told they are investing in cryptocurrencies. They would probably make what would appear to be an instant profit, then be encouraged to put in more and more in to make bigger returns. Of course, in reality there is no investment; there are no returns. You would find out you had been duped only when you tried to take out your money.
The government is under pressure to reform Companies House registration rules to tackle fraud. Barrow, who has worked to help banks to ensure their security is up to scratch, said: “The ease with which a company can be incorporated in the UK, coupled with the total lack of verification required from either the directors or owners of the company, creates a perfect storm for criminals, corrupt actors and scammers around the world to hide behind the facade of a ‘reputable’ UK company. “Locally and globally, crimes that carry huge rewards and which have appalling social impact are being perpetrated behind this façade. It is a national disgrace that we allow it to continue.”
On the trail of Britain’s 400 fake banks
Ali Hussain finds no trace of the 30 firms registered on one London street
Ali Hussain
The Times (March 12 2022)
Summary: Eaton Square in Belgravia is one of the most high-profile addresses in London. Buckingham Palace is down the road. But according to Companies House, the official register of UK firms, it also has the greatest concentration of banks in the country with more than 30 registered (incorporated) since January last year, many next door to each other. There are about 200 banks with addresses in residential streets in a single square mile in London, and pockets in other cities such as Manchester and Edinburgh to take the total up to 400. These are not banks that you will have heard of and they are not registered with the Financial Conduct Authority (FCA), the City regulator. That is because most are probably scams, often involving cryptocurrency, and they are at the heart of a financial crimewave that is costing consumers £28,000 an hour.
What is going on? Being registered at Companies House gives a firm an appearance of authenticity so that anyone who checks can see that it actually exists. It helps scammers appear to have a legitimate business when they try to convince someone to put their money into phoney savings bonds, investments and cryptocurrency. Graham Barrow, a fraud investigator who compiled the list of 400 “banks”, said: “We have a system in the UK that allows anyone, anywhere in the world, to incorporate a company here but which brings no economic benefit to the country. None of the information supplied at the formation of the company is verified. Every single detail might be wrong. They can say a name, who the business owner is and where they live but we have no idea if that is true or not. They could say they live in Peterborough, but really live in St Petersburg, and we simply would not know and do not check.”
Companies House sends a letter to confirm the details. Barrow said: “Even if the letter is returned as “this company does not live here”, the time it takes to get it removed from the register is ample for the criminals to download a PDF of the incorporation document and shove it on their website to “prove” it is a legitimate company.” An investigation by Money into a company called Cryptomeriacoin showed how the scams work. It set up a website purporting to sell cryptocurrency, showing off its Companies House certificate of incorporation as proof of existence at an address in Eaton Square that it was never based at.
A quirk of company law is that you only have to register a bank with the FCA if you actually want to have “bank” in the company name. But when you register with Companies House you are required to list what kind of business you are and can choose “bank” without anyone checking. No checks are carried out by Companies House when someone wants to register a firm. For about 80 of the banks on Barrow’s list, the nationality of the company owner is described as “unknown” on the register. Banks have been registered recently by Russians, Iranians and Chinese citizens.
The bonds or cryptocurrency offered by these firms never actually exist. By the time the scam is discovered and the website shut down, the money transferred to the scammer’s bank will have been moved around the world, making it almost impossible to track down. Victims can be denied refunds because they authorised a transfer of their money. The scammer is untraceable because all their details are fake.
Fraudsters of the world, come to London. And bring your dirty money
Kleptocrats love this country, knowing full well they’ll be free from proper scrutiny
Nick Cohen
The Guardian (4 Dec 2021)
Extract: The law, PR, City, estate agency and banking know that easy riches come from serving the large part of the world where it pays to forget Balzac’s warning that the secret of a great fortune no one can explain is invariably an undetected crime. For want of an agreed name I propose “Corruptistan” to cover Russia and the ex-Soviet states, the kleptocracies of Africa and the Middle East and probably soon China as the communist elite learns how to expatriate its wealth.
Britain has benefited so greatly from the corrupt we may soon be at a stage where we can't afford to clean ourselves up. Given the secrecy of the financial system, the defunding of the police and regulatory authorities and the English libel law, no one can say how many in the UK are living off immoral earnings. But two statistics and one quotation give us a measure of the UK’s dependency culture. Graeme Biggar, of the National Economic Crime Centre, said a “disturbing proportion” of criminal money from the old Soviet Union is “laundered through UK corporate structures”. Companies House, meanwhile, has become a front organisation for organised crime. So welcoming is it to criminals that 335,000 of its listed companies do not reveal the name of their beneficial owners. And 4,000 of the names it appears to reveal turn out on close inspection to belong to children aged two or under.
Likewise, the government has said it wants to stop Companies House being a crime scene where anyone can set up a firm without proof of identity or the most cursory checks. Even the Conservative party appeared to agree that it should not be harder to apply for a passport than to set up a shell company. But once again nothing happened. As for the recommendations in the Russia report on money laundering, they vanished as soon as they were made. You cannot profit from economic crimes committed abroad while enjoying the rule of law at home. The presence of the global plutocracy’s valets at the top of government and society shows the UK no longer even bothers to pretend that it can.
Britain has become addicted to dirty money
Loudly proclaiming new sanctions on Russia will do very little to curb the laundering and fraud
Edward Lucas
The Times (January 31 2022)
https://www.thetimes.co.uk/article/britain-has-become-addicted-to-dirty-money-h9lfl67r6
Extract: In a bleak landscape, Britain stands out. We are bolstering our military presence in Estonia, sending arms to Ukraine and stiffening soggy European spines. Our defence secretary Ben Wallace excoriates the “skewed and selective” reasoning behind Vladimir Putin’s revanchism. The foreign secretary, Liz Truss, is promising new sanctions on Russian energy companies and oligarchs. The message is clear: Britain is the proud linchpin of the Atlantic alliance and the international security order. Behind the bombast is another, uglier story, in which Britain stands out not for its mettle in resisting the Russian regime but for aiding and abetting it. Kremlin cronies have for years used London to launder their reputations and ill-gotten gains.
‘London laundromat’: how golden visa scheme created UK haven for dirty money
Wealthy investors, many with links to Putin, could gain open access to the UK business and social scene under 2008 scheme
Rupert Neate
The Guardian (Feb 17, 2022)
Extract: Javadova, a cousin of the Azerbaijani president, Ilham Aliyev, and a daughter of a former Azerbaijani MP, was granted a “tier 1 investor visa” during a “blind faith period” between 2008 and 2015, when 97% of investors were subject to scant checks on the legitimacy of their wealth. More than 3,000 people were granted investor visas during this period, including 705 Russians. They include:
UK to scrap ‘golden visas’ in crackdown on money laundering
Longstanding review of rules allowing wealthy investors to live in Britain accelerated after Russian action over Ukraine
Financial Times
Laura Hughes and Robert Wright
https://www.ft.com/content/f990e61f-ece8-4bc9-91d9-58fee67e2ba3
Extract: The UK is preparing to abolish its so-called “golden visa” regime within weeks, as Russian actions over Ukraine spurred renewed calls to tackle “dirty money” flooding into the UK. The Tier 1 “investor visa” route has in the past attracted wealthy Russian and other international investors, who have resettled in the UK under the scheme. The visas have been under review since the UK’s relations with Russia deteriorated after the poisoning of former Russian agent Sergei Skripal in Salisbury in 2018. The rules to qualify for investor visas — under which people must show they have at least £2mn to invest in the UK — were tightened up in 2015 and checks on how applicants obtained their money were introduced. Since 2019, applicants must also have proof of a UK bank account.
However, allies of home secretary Priti Patel said she was keen to scrap the whole regime due to concerns the system could be exploited by those laundering illicit funds. Government officials confirmed plans were being drawn up to scrap the visas within weeks. Parliament’s intelligence and security committee warned in 2020 that “the exploitation of the UK’s investor visa scheme” was a draw for many Russians. It said the UK had provided “ideal mechanisms” for the recycling of illicit finance, adding it had become a “laundromat” for offshore wealth. The government issued 798 investor visas in the 12 months to September 2021, 82 of which were awarded to Russians. Over the same period, 210 visas were issued to Chinese nationals.
UK: Russia Ukraine Tensions Forces Restrictions on Golden Visas aimed at Money Laundering
February 16, 2022, published by The Financial Times.
Extract: The UK is getting ready to abolish its so-called “golden visa” regime within weeks, as Russian actions over Ukraine spurred renewed calls to deal with “soiled cash” flooding into the UK. The Tier 1 “investor visa” route has prior to now attracted rich Russian and different worldwide traders, who’ve resettled within the UK underneath the scheme. The visas have been under evaluation since the UK’s relations with Russia deteriorated after the poisoning of former Russian agent Sergei Skripal in Salisbury in 2018.
The foundations to qualify for investor visas — underneath which individuals should present they’ve a minimum of £2mn to spend money on the UK — had been tightened up in 2015 and checks on how candidates obtained their cash had been launched. Since 2019, candidates should even have proof of a UK checking account. Nonetheless, allies of house secretary Priti Patel stated she was eager to scrap the entire regime resulting from issues the system might be exploited by these laundering illicit funds. Authorities officers confirmed plans had been being drawn as much as scrap the visas inside weeks.
烏克蘭局勢：BBC 事實核查
在英國究竟有多少俄羅斯錢
BBC 中文網（2022 年 2 月 20 日）
https://yahoo-news.com.hk/BBCChineseNews/28233/?yptr=yahoo
節錄：俄羅斯富豪為何到英國投資？長期以來倫敦一直吸引許多俄羅斯富豪前來定居、購買房產和投資。英國政府的「黃金簽證」（T1 投資簽證）讓投資 200 萬英鎊或以上的外國富豪取得英國居留簽證，並允許其家人依親。持有居留簽證的人可以再申請英國永久居留權，所需要的居留年限按照投資金額有不同的要求：投資 1000 萬英鎊者，只需要兩年就能申請永居；投資 500 萬英鎊者，需要三年時間就能申請永居；投資 200 萬英鎊者，需要五年時間就能申請永居。自從 2008 年推出黃金簽證以來，英國內政部已經向 14516 名俄羅斯公民核發投資簽證。英國政府表示，如果俄羅斯對烏克蘭發起軍事行動，目前對俄羅斯的制裁將會擴大。外交部表示，英國將會緊跟在美國和其他盟友的步伐，凍結俄羅斯資產和限制旅行。和克里姆林宮相關的個人將受到制裁，其英國資產會被凍結，並被禁止進入英國，禁止與英國企業或個人做生意。
UK: MP John Penrose warns London is ‘Dirty Cash’ EpicenterFebruary 10, 2022, published by openDemocracy
https://i-aml.com/news/uk-mp-john-penrose-warns-london-is-dirty-cash-epicenter/
Extract: The Conservative MP writes today on openDemocracy that urgent action is needed to stop ‘growing’ levels of fraud. The UK government’s anti-corruption tsar has called the City of London “a magnet for dirty cash” and warned that online fraud is growing.
Writing today for openDemocracy, Conservative MP John Penrose appeared to rebuff the business secretary, Kwasi Kwarteng, who recently suggested that fraud is not something that “people experience in their daily lives”. In his piece for openDemocracy, Penrose wrote: “Further postponing the Economic Crime Bill would have sent a message to the oligarchs, kleptocrats and crime lords that it was business as usual for them in London.” He added: “With Russian troops massing on the border of Ukraine, any signs of less-than-steely will to back up our threat of sanctions against Russian oligarchs could send precisely the wrong message to Vladimir Putin. After all, it’s much harder to grab an oligarch’s cash if you don’t know where it’s being kept in the first place.”
openDemocracy reported last month how the official companies register is littered with fake names, because no identity checks are required. They include the director of a small company near Heathrow Airport who gives his name as ‘Holy Jesus Christ’. Legal documents give his occupation as ‘Creator’, his nationality as ‘Angelic’, and his country of residence as ‘Heaven’. Another active company’s directors include ‘Adolf Tooth Fairy Hitler’, while a Saudi Arabian laborer called Donald Duck is said to run a sales firm in south London.
The UK can sanction Russian luxury property. But will it?
As tension heightens over Ukraine, experts say targeting the Russian elite’s UK property would be difficult – and could be a ‘nuclear option’
Thomas Rowley
openDemocracy (16 February 2022)
https://www.opendemocracy.net/en/odr/uk-sanction-russian-luxury-property-ukraine/
Extract: A luxury mansion in leafy Surrey owned by a pro-Kremlin oligarch. A central London penthouse property controlled by a former Russian public official. These are among the high-value, Kremlin-linked UK properties that the British government could target with its new Russian sanctions legislation – if it wishes to do so. Russian businesspeople and officials accused of corruption or links to the Kremlin own at least 150 properties worth £1.5bn, according to Transparency International. If those individuals were sanctioned, the economic use of their assets, including property, would be frozen. Sanctioned individuals would not be able to sell, rent or remortgage their property to free up capital.
Michael O’Kane, head of business crime at law firm Peters & Peters, suspects that the UK government has already drawn up a list of targets in case – in the words of Boris Johnson – the “first Russian toecap” crosses into Ukraine. To designate someone under UK sanctions, the foreign secretary must put forward their name and supporting evidence of their involvement in a sanctionable activity.
Opinion
How Russians Launder Stolen Money Through Real Estate
AMANDA
ABRAMS
Newsweek
ON 12/21/15
Extract: The numbers are staggering: Annually, $1 trillion is stolen by corrupt officials from countries around the globe. That money needs to be spent, or laundered, and much of it goes into big, anonymous real estate deals in the United Kingdom, which is seeing $1.5 billion in unrecorded capital inflows per month. The main source of that money? Russia. From Russia with Cash, a new documentary that aired at the Newseum in Washington, D.C., on December 15, focuses squarely on the phenomenon. It examines up close British real estate agents' willingness to overlook a deal's potential illegality in the hopes of a big commission.
約翰遜：若俄侵烏
將阻止俄公司以英鎊和美元交易
RTHK 2022-02-20
https://news.rthk.hk/rthk/ch/component/k2/1634817-20220220.htm
節錄：英國首相約翰遜表示，如果俄羅斯入侵烏克蘭，美國和英國將切斷俄羅斯的公司獲得美元和英鎊的渠道。他說，英國對俄羅斯實施的制裁將比以前公布的範圍更廣泛，英國和美國將阻止俄羅斯公司以英鎊和美元交易，形容此舉的影響將是「非常非常嚴重」。約翰遜接受英國廣播公司訪問時又說，有證據表明，俄羅斯正計劃 1945 年以來歐洲最大的戰爭，在某種意義上，這計劃已經開始。
Putin Orders Russian Troops Into Ukraine’s Breakaway Provinces
Russia’s president recognizes the regions and sends in “peacekeepers.”
By Robbie Gramer, Jack Detsch, and Amy Mackinnon
Foreign Policy (February 21, 2022)
https://foreignpolicy.com/2022/02/21/ukraine-russia-recognizes-breakaway-provinces/
Extract: Russian President Vladimir Putin
ordered so-called peacekeeping troops onto Ukrainian soil on Monday night, just
hours after giving a lengthy, rambling speech laced with conspiracy theories
and falsehoods—announcing Moscow would formally recognize Ukraine’s breakaway regions in the eastern province of Donbass.
英國宣布制裁 5 間俄國銀行和 3 名富商
RTHK 2022-02-23
https://news.rthk.hk/rthk/ch/component/k2/1635252-20220223.htm
節錄：俄羅斯承認烏克蘭東部兩個分離地區的獨立地位之後，英國宣布制裁 5 間俄國銀行和 3 名與俄羅斯總統普京關係密切的俄國富商，意味被制裁者在英國持有的資產都將被凍結，個人也將被禁止進入英國。首相約翰遜說，這是第一波行動。他形容俄羅斯正被孤立，又說全世界必須準備面對普京的下一個階段計劃，認為俄羅斯正為全面入侵烏克蘭做準備。
UK fast-tracks law to tackle Russian 'dirty money'
By Beth Timmins
Business reporter, BBC News
28 February 2022
https://www-bbc-com.cdn.ampproject.org/c/s/www.bbc.com/news/business-60549927.amp
Extract: The UK is fast-tracking legislation to target money-laundering by foreign oligarchs. The government's move follows Russia's decision to invade Ukraine. As part of the measures, foreign property owners will have to declare their identities rather than using companies as a façade. It follows the economic sanctions announced by Prime Minister Boris Johnson on Tuesday which targeted major Russian banks and leaders. The government said the legislation will support the National Crime Agency work in targeting corruption. The Economic Crime Bill will include a new register that will mean foreign owners of UK property must declare and verify their identities with Companies House.
The aim is to stop overseas criminals and oligarchs from using agents to create companies or buy property for them in the UK. Entities that refuse to declare their owners will face restrictions in selling property and those who break the rule could be imprisoned for up to five years. The register also applies to property bought by overseas owners up to 20 years ago in England and Wales and from December 2014 for property in Scotland. Companies House will also have more information on firms to increase corporate transparency, the government said. On Monday the business secretary Kwasi Kwarteng said that agents from overseas would no longer be able to create UK companies on "behalf of criminals". The process to register a new company in the UK can cost as little as £12.
Butler to the World: The book the oligarchs don't want
you to read - how Britain became the servant of tycoons, tax dodgers, kleptocrats and criminals
Oliver Bullough (Author)
Summary: How did Britain become the servant of the world's most powerful and corrupt men? From accepting multi-million pound tips from Russian oligarchs, to enabling Gibraltar to become an offshore gambling haven, meet Butler Britain...
The Suez Crisis of 1956 was Britain's twentieth-century nadir, the moment when the once superpower was bullied into retreat. In the immortal words of former US Secretary of State Dean Acheson, 'Britain has lost an empire and not yet found a role.' But the funny thing was, Britain had already found a role. It even had the costume. The leaders of the world just hadn't noticed it yet.
Butler to the World reveals how the UK took up its position at the elbow of the worst people on Earth: the oligarchs, kleptocrats and gangsters. We pride ourselves on values of fair play and the rule of law, but few countries do more to frustrate global anti-corruption efforts. We are now a nation of Jeeveses, snobbish enablers for rich halfwits of considerably less charm than Bertie Wooster. It doesn't have to be that way.
Russian President Vladimir Putin: Fortune Freeze when Found
February 27, 2022, published by The Calcalist.
https://i-aml.com/news/russian-president-vladimir-putin-fortune-freeze-when-found/
Extract: Based on Browder, the West could hurt Putin’s fortune through a circle of associates, a claim that has risen again since the escalation. “Putin made a deal with the Russian elite. ‘Give me 50 percent of your capital and I’ll let you keep the remaining 50 percent,” according to Browder, who told Forbes. “If not, he will take the 100 percent and throw them in jail.” Although Putin’s name did not come up in the Panama Papers leak in 2015, some of his closest friends, it was revealed, hold hundreds of millions of dollars in tax havens. According to Browder, the most effective way to impose sanctions on Putin is to go against the 50 or so oligarchs who run Putin’s fortune. “That’s what will stop him,” he tweeted.
British Prime Minister Boris Johnson on Tuesday unveiled a round of sanctions he described as “the largest and most severe package of economic sanctions ever imposed on Russia”. Johnson told lawmakers that Putin is an “attacker with blood on his hands” who will suffer condemnation from all over the world and history due to the invasion of Ukraine. The sanctions include the freezing of assets in the UK by the major banks in Russia and their exclusion from the financial system. This means they will not have access to the British currency and will not be able to transfer payments through the UK. In addition, large Russian companies will not be able to raise capital or borrow money in the British markets. Also the assets of 100 individuals and companies, including Putin’s ex-son-in-law, Kirill Shmalov, and Peter Fredkov, CEO of Promsvyazbank, on which sanctions were also imposed. Uralvagonzavod tanks.Also, Russia’s national airline Aeroflot will not be allowed to land in the UK.
Additional sanctions include a ban on the export of components that could be used for military and civilian purposes, and at the same time the UK will stop exporting items to the high-tech industry and oil refining equipment. Yes, there will be a restriction on Russian deposits in the UK. Johnson concluded by saying that there were still options for further sanctions, including Russia’s removal from the SWIFT payment system. He added that the sanctions would also apply to Belarus due to the assistance it provided to Russia when it allowed it to attack its territory.
Roman Abramovich
Billionaire businessman and oligarch
Known minimum value of assets $8,054,689,267
https://cdn.occrp.org/projects/russian-asset-tracker/en/person/1/roman-abramovich
Reason for inclusion
A power player in Russia since the late 1990s, the oligarch is a former member of parliament and was the governor of the Chukotka region from 2000 to 2008.
As one of Russia’s richest people, he made his fortune buying up Russian oil assets during the privatization wave that followed the end of the Soviet Union. Before he was sanctioned in March 2022, his net worth was reported to be $12.3 billion.
He is perhaps best known internationally as the owner of Chelsea Football Club, which he announced that he would sell in the wake of Russia’s full-scale invasion of Ukraine. He has vehemently denied allegations that he is close to Russian President Vladimir Putin and his government.
List of oligarchs and Russian elites featured in ICIJ investigations
ICIJ’s vast trove of leaked financial data features details on Russian oligarchs, billionaires and political power players, including members of President Vladimir Putin’s inner circle, who are coming under increased scrutiny in light of Russia’s invasion of Ukraine.
By ICIJ
March 20, 2022
China’s Ukraine Crisis
What Xi Gains—and Loses—From Backing Putin
By Jude Blanchette and Bonny Lin
Foreign Policy (2022-02-21)
https://www.foreignaffairs.com/articles/china/2022-02-21/chinas-ukraine-crisis?amp
OPINION
FARAH STOCKMAN
This Is the Russia-China Friendship That Nixon Feared
The New York Times (Feb 20, 2022)
By Farah Stockman
Extract: It’s too early to tell how far China will stick its neck out for Russia in its confrontation with the West over Ukraine. China’s leaders have long argued for a world free of formal military alliances. They’ve been cautious about getting entangled in other countries’ military conflicts. The two countries began edging closer together in 2014, after Russia’s invasion of Crimea prompted Western sanctions. Russia weathered the fallout with some support from China, which beefed up trade and its purchase of Russian oil and gas.
President Putin and President Xi might not be natural allies, but they have an awful lot in common. Both see the United States as a chaotic hegemon. Both men were profoundly shaken by the collapse of the Soviet Union, which they viewed as a cautionary tale of what not to do. Both have clamped down hard on dissent and dispensed with or circumvented presidential term limits, paving the way for the potential to rule for life. And both, longing to restore their countries’ role as great powers, are striving to recover territory that they see as having been lost to the West: Ukraine, in Russia’s case, and Taiwan, in the case of China.
Beware Comparisons of Ukraine and Taiwan
By Andrew Browne
Bloomberg (2022-02-19)
Extract: China’s leader Xi Jinping calls Vladimir Putin his “best friend.” They do have plenty in common. They’re both “strong men” running authoritarian regimes who are setting themselves up to rule for life. And they’re united by one all-consuming mission: to restore lost national glory.
China says Taiwan is 'not Ukraine' as island raises alert level
Reuters (Feb 23, 2022)
Extract: Taiwan is "not Ukraine" and has always been an inalienable part of China, China's foreign ministry said on Wednesday, as Taiwan President Tsai Ing-wen called for the island to beef up vigilance on military activities in response to the crisis. The comments come after British Prime Minister Boris Johnson flagged the risk for Taiwan in a warning last week about the damaging worldwide consequences if Western nations failed to fulfil their promises to support Ukraine's independence.
個人存取現金超 5 萬需登記
人民銀行回應：旨在反洗黑錢
星島網 2022-02-11
https://std.stheadline.com/realtime/article/1807369/
節錄：內地 3 月 1 日將施行的《金融機構客戶盡職調查和客戶身份資料及交易記錄保存管理辦法》，商業銀行、農村合作銀行、農村信用合作社、村鎮銀行等金融機構為客戶辦理人民幣單筆 5 萬元以上或者外幣等值 1 萬美元以上現金存取業務的，應當識別並核實客戶身份，了解並登記資金的來源或者用途。人民銀行有關司局負責人日前明確回應，個人現金存取相關規定旨在預防和遏制洗錢等違法犯罪活動，保護人民群眾資金安全和利益，同時相關規定不會影響居民正常現金存取款業務，居民存取現金便利程度不會受到影響。
個人存取現金超 5 萬要登記
是否給存取款帶來不便？
來源：人民網（2022 年 2 月 10 日）
http://sh.people.com.cn/BIG5/n2/2022/0210/c176738-35128959.html
節錄：有網友認為此舉讓存取款手續更為繁瑣，給業務辦理帶來麻煩 ﹔也有網友認為這會侵犯居民的隱私。針對相關質疑，人民銀行有關負責人近日對出台該規定的考慮已經規定的影響進行了解讀。該負責人表示，從統計上看，目前我國超過 5 萬元人民幣的現金存取業務筆數僅佔全部現金存取業務的 2% 左右，《金融機構客戶盡職調查和客戶身份資料及交易記錄保存管理辦法》第十條的規定總體上看對客戶辦理現金業務影響較小。金融機構執行該規定不會影響居民正常現金存取款業務，業務便利程度亦不會受到影響。規定的主要目的是預防和遏制洗錢等違法犯罪活動，保護人民群眾資金安全和利益。
主要目的是預防和遏制洗錢等違法犯罪活動。該規定出自人民銀行、銀保監會、証監會 1 月 26 日聯合印發的《金融機構客戶盡職調查和客戶身份資料及交易記錄保存管理辦法》（中國人民銀行 中國銀行保險監督管理委員會 中國証券監督管理委員會令〔2022〕第 1 號，以下簡稱 “ 1 號令”），《辦法》自 2022 年 3 月 1 日起施行。據央視財經消息，人民銀行有關司局負責人日前對 “1 號令”第十條關於個人現金存取規定進行了解讀。該負責人表示，實施 1 號令的主要目的是預防和遏制洗錢等違法犯罪活動，保護人民群眾資金安全和利益。
近年來，電信詐騙、非法集資、非法傳銷、跨境賭博、地下錢庄等違法犯罪活動較為猖獗，嚴重危害人民群眾利益。僅 2021 年，公安機關共偵辦電信詐騙案件 37 萬余起，受害者遍布全國各地。其中，一個突出的特征就是犯罪分子利用現金匿名、難以追蹤的特點，偏好使用現金進行交易活動。金融機構依法適當加強對現金存取款活動的管理，有利於防范違法犯罪活動，有利於保護最廣大人民群眾的根本利益。從實踐經驗看，近年來我國金融機構不斷加強洗錢風險管理，發現了不少涉嫌違法犯罪活動的情形，保護了人民群眾資金安全。
Russian firms rush to open Chinese bank accounts amid Ukraine crisis
Source: Reuters (Mar 3, 2022)
Summary: The Moscow branch of a Chinese state bank has seen a surge in enquiries from Russian firms wanting to open new accounts, a person familiar with the matter said, as the country's businesses struggle with international sanctions after its invasion of Ukraine. "Over the past few days, 200-300 companies have approached us, wanting to open new accounts," the person, who works at the Moscow branch of a Chinese state bank and has direct knowledge of its operations, told Reuters. He declined to be named or have his bank identified as he is not authorised to speak with media.
It was not clear how widespread Russian demand for new accounts at Chinese banks was, but the banker source told Reuters many of the companies seeking new accounts do business with China and that he expected yuan transactions by such firms to increase. Western governments are shutting off Russia's economy from the global financial system, pushing international companies to halt sales, cut ties and dump tens of billions of dollars' worth of investments. China has repeatedly voiced opposition to the sanctions, calling them ineffective and insisting it will maintain normal economic and trade exchanges with Russia.
Russian banks are seeking refuge in a Chinese payment system
By Jane Li
Qz.com (Published March 7, 2022)
https://qz.com/2138460/russian-banks-are-seeking-refuge-in-a-chinese-payment-system/amp/
Summary: As western companies continue to suspend operations or withdraw from Russia due to its invasion of Ukraine, China has become a possible Plan B. Russian banks that include Sberbank, the country’s largest bank by assets, and Alfa Bank said on Sunday (March 6) that they are exploring the possibility of issuing “co-badged” cards powered by payment systems like Chinese state-owned UnionPay and Russia’s Mir for international payments, according to Russian state news agency TASS. Sberbank said it will soon reveal a launch date for such cards, while Alfa bank said it is already “at work” on launching cards based on UnionPay. Russian lender Tinkoff Bank also has similar plans, TASS reported.
The banks’ announcement came after Visa, Mastercard, and American Express said they are suspending operations in Russia, which has been put under sweeping financial sanctions from countries including the US and UK. Within Russia, cards issued by Visa, Mastercard, and American Express can still be used until they expire, but the same cards will no longer work for payments outside the country. Nor will credit cards issued outside of Russia be usable at the country’s stores or ATMs.
Top Ten Most Common Russian Sanction Evasion Schemes
Integrity Risk International
https://integrityriskintl.com/top-ten-most-common-russian-sanction-evasion-schemes/
Summary: There is a wide range of tactics that Russia uses to evade US sanctions, and it’s important to understand that there are both legal and criminal attempts to evade the consequences of Russian sanctions. Our experts, Tom Firestone and Duncan Nott, have drilled down to the 10 most common criminal sanction evasion schemes that organizations need to be prepared for.
1. Concealed Russian oil origins
2. Intermediary trading through other countries
3. “Debit-card tourism”
4. Import of goods without trademark owner consent
5. Electronic part purchases for further assembly
6. Alternative payment systems
7. Bilateral companies
8. Foreign companies paying in rubles
9. Corporate restructuring and liquidation
10. Central Asian accounts and subsidiaries
長實近 124 億港元出售倫敦物業RTHK 2022-03-11
https://news.rthk.hk/rthk/ch/component/k2/1638498-20220311.htm
節錄：長實表示，以 12.1 億英鎊，相當於 123.9 億港元，出售倫敦 5 Broadgate 物業。集團說，於 2018 年 6 月以 10 億英鎊購入，連同整體持有期內的租金收入、物業升值及這項投資的對沖利潤，投資 3 年半以來總回報約 48 億港元，投資回報 45%。長實執行委員會成員馬勵志表示，集團負債比率低，現金充裕，出售有關倫敦物業後，負債比率將進一步下降，將繼續在不同地區，包括香港及內地，物色更多新投資機會，形容全世界都是集團的潛在市場。
Belfast: Ten sentenced over £20m money laundering scheme
BBC (18 July 2022)
https://www-bbc-com.cdn.ampproject.org/c/s/www.bbc.com/news/uk-northern-ireland-62213522.amp
Extract: Ten people have been sentenced over a £20m money laundering scheme after an investigation found significant sums of cash laundered via NI-based accounts. The six men and four women are Chinese nationals and all of them lived in Belfast at the time of the offences.
The judge at Belfast Crown Court said "staggering amounts of cash" were seized from some of the accused. Seven of the defendants were jailed for their role in the scheme while the other three got suspended sentences. The offences were uncovered during an investigation by the National Crime Agency (NCA) which involved a number of UK-based financial institutions. During the case, it emerged that a branch of Barclays bank in Belfast was being used by the defendants to make frequent large cash deposits.
Following arrests in July 2019, 10 suspects were charged with offences including converting criminal property, possessing criminal property and entering an arrangement to acquire criminal property.
The new money rescuing London's property market from Russian retreat
Golden visas and bulging bank accounts are opening doors for a new clientele
By Matt Oliver
The Telegraph (23 July 2022)
Extract: As Britain’s authorities cracked down on Russian oligarchs’ assets and influence, the picture for estate agents who long furnished them with luxurious London pads may at first have seemed bleak. But those clutching their pearls for the capital’s realtors can rest easy, for they have been saved by a new favourite clientele: the Chinese investor. Property hunters from Hong Kong and China’s mainland have been filling the void as far more circumspection is applied to Russian money, swooping on prime central London. “Russian money is pretty much yesterday,” says Beauchamp Estates’ Paul Finch. The number of new Russian buyers has tumbled over the past four or five years, with scrutiny having increased gradually after the Skripal poisonings and then massively after the invasion of Ukraine. “The Chinese have definitely taken up the slack. They have been quite prolific, especially the Hong Kong Chinese, in buying up properties in London,” he adds.
In 2021, all of the city’s top five super-prime property deals – or those worth £20million or more – involved Chinese billionaires, according to research by Beauchamp. That was ahead of Russians, Americans, Britons and Africans, who made up the rest of the list. As ever, one of London’s big draws is its private schools and cultural offering. Deals in recent years have concerned some of the capital’s most prestigious properties. In 2020, Cheung Chung-kiu （張松橋）, a Hong Kong property magnate who also owns the “Cheesegrater” skyscraper, snapped up 2-8a Rutland Gate, the Knightsbridge mansion overlooking Hyde Park. It cost more than £200m – making it the most expensive property ever sold in the UK. Elsewhere, Wang Jianlin （王健林）, the founder of real estate, finance and movie theatre giant Dalian Wanda Group （大連萬達集團）– whose fortune is estimated at £10bn – forked out £80m for a Grade II-listed home in Kensington Palace Gardens. It has been dubbed London’s most desirable street, just down the road from Russian oligarch Roman Abramovich. The ten-bedroom Victorian home was previously occupied by Ukraine-born businessman Leonid Blavatnik and was leased by the Crown Estate.
Chinese citizens have become the biggest users of the UK’s “golden visa” scheme, which allows investors to pay £2m in exchange for at least three years of residency and later a path to citizenship. Applicants from China have received 33pc of the so-called tier 1 visas issued since the scheme was launched in 2008, ahead of the 19pc issued to Russians. According to Transparency International, a total of 1,624 visas have been issued to Chinese applicants and a further 2,623 to their dependents such as family members.
Yet as Russian buyers recede with sanctions and anti-corruption investigators on their tail, there are inevitable questions over whether Chinese money may also come back to bite. With so much dirty cash thought to have washed through London, the capital has already earned the unenviable nickname “Londongrad” for its seeming ability to look the other way. Campaigners say the political realities in China should give estate agents some pause for thought. The heads of MI5 and the FBI recently warned that due to the Communist Party’s pervasive influence, it is sometimes impossible to distinguish between the state and the private sector.
Financial Times
London’s Most Expensive Home “owned by Evergrande founder”
Hui Ka Yan may sell mansion overlooking Hyde Park after suffering reversal in fortunes
George Hammond in London and Primrose Riordan in Hong Kong
https://www.ft.com/content/e38f49e3-b8e2-4690-8e60-2b032d41dafa
Extract: London’s most expensive house is owned by the head of embattled Chinese property group Evergrande, according to people familiar with the secretive £210mn sale that was struck just before Covid-19 hit the UK. The 45-room mansion overlooking Hyde Park was sold by the estate of the former Saudi Arabian crown prince Sultan bin Abdulaziz for its record-breaking price in January 2020.
The public face of the acquisition of 2-8a Rutland Gate was Cheung Chung-kiu（張松橋）, a Chinese property developer whose company CC Land owns London’s “Cheesegrater” skyscraper. However, according to five people familiar with the matter, Hui Ka Yan（許家印）, the founder and chair of Evergrande （恒大集團）and once China’s richest man, was ultimately behind it.
Hui and Cheung are part of a well-known circle of Hong Kong tycoons who played cards and socialised together. The pair have had multiple business dealings over the past decade and CC Land has previously sold projects on the mainland to Evergrande.
The London house sale involved a British Virgin Islands company called Vision Perfect Global Ltd buying the property from Curaçao-registered Yunak Property Corp, according to Land Registry documents.
Two CC Land executives are named as directors of a related UK-based company; a person recorded in February 2020 as holding 75 per cent or more of the company is Ding Yumei（丁玉梅）, Hui’s wife. CC Land said the company was connected to the property but does not own it. Evergrande and Hui did not respond to a request for comment.
許家印傳持有倫敦最貴豪宅
Infocast (2022 年 10 月 7 日)
節錄：英國《金融時報》引述知情人士報導，倫敦最貴豪宅的實際所有人是恒大集團（港股編號：3333）創辦人許家印。該筆 2.1 億英鎊的豪宅交易是在新冠疫情爆發前完成。購買倫敦 2-8a Rutland Gate 超級豪宅的公開面孔是中國房地產商人 Cheung Chung-kiu（張松橋），後者旗下的公司 CC Land 擁有倫敦摩天大樓「Cheesegrater」。知情人士稱，實際幕後所有人是許家印。根據英國土地註冊處的文件，英屬維爾京群島註冊的名為 Vision Perfect Global Ltd 的公司從 Curaçao 註冊的 Yunak Property Corp. 購買這間超級豪宅。兩位 CC Land 的高層獲委任為一家英國相關公司的董事，2020 年 2 月的紀錄顯示許家印的妻丁玉梅擁有這家公司 75% 或以上股份。該超級豪宅正在出售，但未進入正式出售程序。
相關的文章：
金融中心的黑暗面
2020 年 1 月 15 日
https://xiaoshousha.blogspot.com/2020/01/blog-post.html
節錄：外國學者用倫敦做例子，說明金融業過度膨脹之後所帶來的問題：來自共產主義國家（中國和俄國）的黑錢氾濫，令樓價飆升至不合理水平，金融業跟其他行業爭奪資源和人才（而非支援實體經濟的發展），令實體經濟失去生存空間或被掏空或變成賭博工具。金融業發達有助官商勾結（因為利益交換可以透過金融市場進行），危害民主與自由，加劇貧富懸殊（因為權貴可以合法避稅但是打工仔無法避稅），影響社會流動。
離岸中心（二）
2009 年 1 月 4 日
http://xiaoshousha.blogspot.hk/2009/01/blog-post_04.html
節錄：近年俄羅斯黑幫被英語傳媒冠名 The Communist Mafia（共產黨式黑手黨），他們在西方的影視作品中往往被描寫為十惡不赦的壞蛋。他們的影響力開始滲入國際體壇，例如：俄羅斯富豪、英超球隊車路士 (Chelsea) 的班主艾巴莫域治 (Roman Abramovich)，他的財產據說就來自賤價收購國有資產。有評論認為，俄羅斯黑幫既擁有全球網絡，又掌握了國防技術，威脅程度比正牌恐怖份子更大，論實力絕不遜於恐怖大亨拉登 (Osama Bin Laden)。
離岸中心（三）
2009 年 1 月 11 日
http://xiaoshousha.blogspot.hk/2009/01/blog-post_11.html
節錄：透過英國或者歐洲的金融體系匿藏和調動資產的，當然不止前蘇聯的共產黨官僚，還有來自世界各地的貪官和政客，他們都懂得利用西方的銀行系統，在海外建立小金庫，為自己及家人舖定後路。而香港作為國際金融體系的一份子，又跟大英帝國有深厚淵源，在資金的流轉過程中，也扮演了一定的角色。近期的例子，有泰國前總理他信 (Thaksin Shinawatra) ，還有「台灣之恥」陳水扁一家。
Kleptocracy（盜賊統治）
2021 年 8 月 20 日
https://xiaoshousha.blogspot.com/2021/08/kleptocracy.html
節錄：盜賊統治 (Kleptocracy) 跟洗黑錢活動關係密切，有如連體嬰，或錢幣的兩面。Kleptocrats 是指貪污腐敗的當權者（竊國者），這個詞經常在英語傳媒對於洗黑錢活動的調查報導中出現。金錢無國界，竊國者透過離岸公司及複雜的股權結構，把不義之財轉移至對資產提供較佳保障的西方國家，然後隱藏起來。竊國者要保護自己的權力以及家族利益，必定會全力摧毀本國的法治及設法打壓公民社會，同一時間卻享受著西方國家所提供的法律保障，卑鄙無恥，對不對？
Pandora Papers
2021 年 10 月 4 日
https://xiaoshousha.blogspot.com/2021/10/pandora-papers.html
ICIJ links for readers interested in offshore finance:
諜影
2016 年 4 月 22 日
http://xiaoshousha.blogspot.hk/2016/04/blog-post_22.html
節錄：根據 Washington Post 的報導，負責分析文件的國際調查記者聯盟 (The International Consortium of Investigative Journalists, ICIJ) 背後的美國公共誠信中心 (Center for Public Integrity)，金主是國際大鱷索羅斯 (George Soros)。他較早前表示會「沽空亞洲貨幣」，令偉大祖國非常緊張，官媒輪流開炮。索羅斯戰績彪炳，利用在金融市場賺來的錢，資助共產黨的對頭人。中國和俄羅斯的領導人首當其衝，被爆陰毒，理所當然。
隱身術
2019 年 9 月 27 日
https://xiaoshousha.blogspot.com/2019/09/blog-post_27.html
節錄：早於 2018 年初中美貿易戰爆發之前，紅色資本的海外併購活動已經遇到困難。西方國家基於國家安全考慮，對中資說不（提示：倫敦交易所），又或者設置障礙。中資的回應方式，是動用港人、台商、南洋華僑甚至親共洋人(Panda Hugger) 當人頭或 Frontman，讓大股東可以退居幕後。
從查冊中學會的事
2021 年 4 月 14 日
https://xiaoshousha.blogspot.com/2021/04/blog-post.html
節錄：見識過這些事情，你會明白現有的監管制度存在很多的漏洞，在香港打工和做生意非常不容易。即使是透過查冊找到某人的名字和完整的身份證編號，還是距離真相很遠。如果把查冊的結果進一步收窄至身份證的頭三位或四位數字，以及禁止某個行業的人（傳媒＋記者）查冊，即是透明度開倒車，結果只會是方便壞人，令企業管治水平下降，也會影響正常商業活動（例如：物業買賣＋收購合併）。難怪國際傳媒和外國人社群負評如潮：
「進階版」求職須知 (Part 5)
2019 年 1 月 10 日
https://xiaoshousha.blogspot.com/2019/01/part-5.html
節錄：無良僱主或中間人（即：人事顧問或獵頭公司）收集求職者的個人資料，然後轉售圖利，是常見的港式求職騙局。常見的做法：填完申請表格，叫你回家等通知，之後音訊全無。也許會約你去面試，但是感覺很假，因為對方的表情和語氣似背對白，是有劇本的。對方也許會在面試過程中耍手段，真正目的是趕你走（因為收集個人資料的任務已經完成），把放棄的責任推卸到閣下身上。
離岸中心（六）
2010 年 8 月 1 日
http://xiaoshousha.blogspot.hk/2010/08/blog-post.html
節錄：理論上，凡是可供巨額資金停泊的投資產品，包括股票、房地產、私人信託、珠寶首飾以及古董文物，都可以成為不法之徒清洗黑錢的工具，人壽保單亦不例外。洗錢者選中一家保險公司，先將贓款交給保險經紀，購買大量的保險單，然後解除保險，保險公司的退款支票到達指定的帳號後，黑錢就被洗淨。
洗黑錢督數偽術
2018 年 4 月 14 日
http://xiaoshousha.blogspot.com/2018/04/blog-post_14.html
節錄：中資機構也懂得洗黑錢，所以有「影子員工」或「影子觀眾」的做法，用來誇大營運開支或票房收入，作用是掩飾資金的去向或來源，亦可以是把維穩費落格或者瓜分（即：食夾棍、內鬼運財）。應用於新聞機構或娛樂事業的話，便是長期不上班但是名字出現於員工名單內，定時支薪的記者編輯，又或者是沒有參與電影製作，但是名字出現於幕後工作人員名單中的大陸人。
金山黑錢
2020 年 5 月 8 日
https://xiaoshousha.blogspot.com/2020/05/blog-post.html
節錄：毒品變成黑錢的載體，作用是把人民幣轉換成美元，而大陸的化工廠負責人和墨西哥的毒販，就收取手續費或服務費作為回報。來自（新）中國的黑錢繞過地面上的合法銀行系統流入了美國，目的地是洛杉磯，跟老一輩廣東人賣豬仔（做苦工）的地點「舊金山」（英語：San Francisco，孫中山叫「三藩市」，美國加利福尼亞州的北部）同屬一個州份。
移形換影
2020 年 12 月 12 日
https://xiaoshousha.blogspot.com/2020/12/blog-post.html
節錄：大陸的金融監管機構高層也不好當，因為即使沒有中美關係惡化蔓延至金融領域這個負面因素，單是日常運作的層面，如何避免中國現有的金融系統被犯罪份子所利用，以及回應數碼貨幣和電子支付 (Digital Currency / Electronic Payment，簡稱 DC/EP) 所帶來的各種挑戰，以免金融科技形成新的系統性風險 (Systematic risk) 隱患（出處：中國銀保監會主席郭樹清），已經是一項非常艱鉅的任務。從監管機構的角度看，新舊夾擊，想起都頭痛。
數碼貨幣 (Part 4)
2021 年 7 月 3 日
https://xiaoshousha.blogspot.com/2021/07/blog-post.html
節錄：中央銀行的當前急務包括：1. 跟科技發展競賽，盡快建立一套可行的監管制度，過程中可能需要修改舊的監管制度及改變背後的思維方式。2. 繼續在現實和虛擬世界中跟壞人鬥智鬥力，保護不熟悉新科技的小市民，才能證明自己的生存價值。3. 御貓抓捕壞人（老鼠）之餘，也要避免扼殺了金融創新的空間，同時還要發展央行數碼貨幣 (Central Bank Digital Currency, CBDC)，以免自己的國家落後於競爭對手，日後被別人所設計的遊戲規則所困。
數碼貨幣 (Part 3)
2020 年 10 月 22 日
https://xiaoshousha.blogspot.com/2020/10/part-3.html
節錄：由於加密貨幣 (Cryptocurrency) 的買賣活動無須經過美元結算體系，另一個常見用途是用來繞過美國的貿易制裁，那是伊朗和北韓的做法。好處是讓受到國際社會孤立的政權可以（透過進行對外貿易或犯罪活動）賺取收入，繼續生存以及發展武器自保，詳情請參考＜延伸閱讀＞部份所提供的英文材料。對，獨裁者也要想辦法賺錢，然後把剝削老百姓所得的錢轉移（洗黑錢），以便在海外建立小金庫，萬一他日被推翻，老婆、情婦和兒孫也有錢用。
數碼貨幣 (Part 2)
2020 年 10 月 7 日
https://xiaoshousha.blogspot.com/2020/10/part-2.html
節錄：在中美關係惡化的背景下，中國央行與其被動地回應，被（國際社會）邊緣化，倒不如採取主動，爭取成為設定行業標準的先行者 (First Mover)，順便把法定貨幣（人民幣）數碼化（提示：化粧＋喬裝＋黃子華），一來保住中國央行的地位，二來保障國家主權及金融安全，三來讓中國可以繼續進行對外貿易（即：對抗美元霸權或繞過貿易制裁），一舉數得。
數碼貨幣 (Part 1)
2020 年 10 月 7 日
https://xiaoshousha.blogspot.com/2020/10/part-1.html
節錄：中美關係惡化又同時牽動了中共內部的派系鬥爭，令局內人覺得危在旦夕，有急切需要尋找新的走資渠道，安排後路及安頓家人。同一時間，疫症蔓延令經濟活動或停頓或半停擺，很多人無法出門，被迫長時間留在家中，透過互聯網跟外面的世界保持聯繫。在這種情況下，不受監管的加密貨幣 (Cryptocurrency) 正好符合大陸貪官的走資需求。
Revised 11/10/2022
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