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There is no doubt high street firms are targeted as they tend to be less sophisticated (not knowing how to conduct ECDD on PEPs for a start) less aware of the routes by which tainted money can be shifted and also perhaps find it harder to turn down a good fee.

In many cases it is very easy to spot 'Ivan' is buying a house worth £2.5m despite not having ever earnerd more than a few thousand roubles per month.

HMLR should look at the registrations of purchasers of high value properties and their owner's profiles, if there is a mismatch it should report the matter to the NCA: my betting is that many of their purchasers would be unable to discharge the shifted burden of an unexplained wealth order.

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