The fight against money laundering has moved in a new and unforeseen direction. All‐crimes money laundering means what it says: the offence‐creating provisions of s. 93A of the Criminal Justice Act 1988 encompasses all crimes, including tax evasion. What is more, it is intended to criminalise the professional adviser who enters into arrangements or provides transactional advice to a client that facilitates the retention of the proceeds of crime, if the adviser suspects the client has been engaged in tax evasion.
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