Monthly Archives: February 2012

I ♥ the FATF (when they prove me right)

Posted on February 29, 2012 by

Unless you have been on retreat in an ashram or stuck in the fog in Guernsey, you will know that the Financial Action Task Force has recently issued a revised version of its 40+9 Recommendations.  For a start, it’s now … Continue reading →

Posted in Legislation, Money laundering, Regulation, Supervision | Tagged , , , , , , | 3 Comments

Hoist by my own petard

Posted on February 27, 2012 by

My, what japes I have had this weekend!  As you may remember, I am planning to publish a little guide to AML for UK non-exec directors – I’ve posted about it before, here and here.  After researching all the options … Continue reading →

Posted in Money laundering, Publications | Tagged , , , , , , | 2 Comments

Off with his head! (Only joking, if you’re a Swiss lawyer)

Posted on February 24, 2012 by

Does anyone else ever feel that we are stuck in a bizarre Alice-in-Wonderland scenario with some of the money laundering stories we see?  One of my news feeds today informed me that Interpol has added Victor Khrapunov to its wanted … Continue reading →

Posted in Bribery and corruption, Money laundering | Tagged , , , , , | 1 Comment

Order, order!

Posted on February 22, 2012 by

Frustration, irritation, restriction and humiliation.  No, this is not my recipe for marital success, but the welcome result of the application of one or more of an array of Orders that the UK’s Serious Organised Crime Agency now has at … Continue reading →

Posted in Legislation, Money laundering, Organised crime | Tagged , , , , , , , , , | 1 Comment

Deficient or just plain black?

Posted on February 20, 2012 by

I’m a big fan of the Financial Action Task Force – I even call them “eff-ay-tee-eff” as I think this is more respectful than “fat-eff”.  But dealing with them, even at my lowly level of simply reading whatever they publish … Continue reading →

Posted in Money laundering, Regulation | Tagged , , , , , , | Leave a comment

Eds and NEDs

Posted on February 16, 2012 by

I know how you clamour to hear the latest sales figures for the adventures of Edward Jones, MLRO-about-town, and what a bumper month we had in January!  I think we can safely make reference to lukewarm cakes, the selling thereof. … Continue reading →

Posted in Money laundering, Publications | Tagged , , , , , | 5 Comments

Selling ice-cream to Eskimos

Posted on February 15, 2012 by

One of the biggest challenges the MLRO can face is that of “selling” AML/CFT to the holders of the purse-strings.  Most Boards now know that they have to do something AML-ish, but some will try to pare it down to … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , | Leave a comment

The joys of tech support

Posted on February 13, 2012 by

I’m rather proud of the fact that I created this blog all by myself.  Granted, it’s not like the old days, when you had to code in, well, code: all I did was choose a pretty template and then bung … Continue reading →

Posted in General thoughts | Tagged , , | 2 Comments

Now let’s share nicely

Posted on February 10, 2012 by

You know organised crime?  Well, it’s crime and – follow me carefully – it’s organised.  I think this major characteristic is sometimes overlooked in all the hand-wringing and gnashing of teeth over how we’re never going to beat it.  A … Continue reading →

Posted in Money laundering, Training | Tagged , , , , , , , , , | 4 Comments

Insatiable blood-sucking monsters

Posted on February 8, 2012 by

No, I’m not talking about our government.  When I first started doing AML training, an older and wiser trainer warned me: “When it comes to case studies, your clients will be insatiable, blood-sucking monsters.”  In fact, the vast majority of … Continue reading →

Posted in Money laundering, Training | Tagged , , , , , , , , , | Leave a comment