Mr Downing is seeking to open a new bank account with Y Bank in London very quickly because he has some cash that he wants to invest and he is concerned that his former bank may be at risk of failure. Y Bank is a small bank and very short of capital and due to the extenuating circumstances, Mr. Zukus, the bank manager, waives the bank’s normal identification procedures. Mr Downing’s account is duly opened and Mr Downing deposits £200,000 each day for 2 weeks in cash. Mr. Downing then transfers £100,000 to a bank in Hong Kong to finance a shipment of cargo, £100,000 to purchase a single premium insurance policy which he cashes in the following week because he says that he is worried about the insurance company failing, £100,000 in a globally diversified equity fund which he cashes in after 2 weeks, £100,000 is transferred to a bank account in the Cayman Islands as he is investing in a hedge fund based there, and £50,000 to a Swiss Bank account.

In light of existing regulatory provisions in the UK discuss the legal implications and potential prosecution for the following:

1. Mr Downing

2. Y Bank

3. Mr Zukus