Category Archives: Due diligence

The blame game

Posted on April 27, 2012 by

This week, for the last time, I watched “The Apprentice”.  What a nasty programme it is.  The two teams competed on some daft task – selling gourmet fast-food in Scotland, I think – and were measured by the amount of … Continue reading →

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Ee bah gum – eVerification of eID

Posted on April 18, 2012 by

Verification of identity is like driving: we all think we know how to do it well, and probably better than other people, but if we were to take our driving test again (and especially the scary written test that the … Continue reading →

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So long, farewell, auf wiedersehen, goodbye

Posted on April 11, 2012 by

As I may have mentioned in passing, I have been busy recently writing books on AML for NEDs (aka the pig in shades).  One of the many pleasures of this project (well, come on – you knew I was AML-batty … Continue reading →

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PEPs cost Coutts dear

Posted on March 28, 2012 by

In its largest-ever financial penalty levied for AML failings, the FSA has fined Coutts & Co £8,750,000 for AML failings.  The full FSA notice is here, and it makes depressing reading – one might have hoped that the banker to … Continue reading →

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Our domestic PEPs don’t know they’re born

Posted on March 21, 2012 by

I don’t know much about South Sudan.  I’m guessing that it’s south of Sudan, and a quick Wiki-search tells me that the capital is Juba, that the whole country is pretty swampy, and that little is known about its fungi. … Continue reading →

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Playing the waiting game

Posted on March 9, 2012 by

Timing is not only the secret of great comedy – it is also the secret of great AML.  There are so many points in the application of AML procedures at which timing is an issue, from the very beginning (when … Continue reading →

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Good cop, bad cop, cr*p cop

Posted on March 7, 2012 by

At least once a quarter, someone in a training session somewhere will ask: “What if I think the MLRO is crooked?  Who should I report to then?”  Of course I explain that legislation always allows for reporting direct to the … Continue reading →

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The spectre at the feast

Posted on November 21, 2011 by

We had someone to stay at the weekend, and she mentioned that her cousin’s daughter’s boyfriend (oh, do keep up) was under investigation in the US for – she thought, hence the revelation – something to do with money laundering. … Continue reading →

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Walk on by

Posted on October 19, 2011 by

The “Today” programme on Radio 4 this morning was full of this story from China.  In short, a toddler was knocked down by a van, and eighteen people walked or cycled past without helping.  Another van then ran over her … Continue reading →

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A criminal – but not too much of one

Posted on October 7, 2011 by

At a recent training session, I was talking about the Bribery Act 2010.  (Normally I try to stick quite closely to money laundering, on the basis that all crimes lead to laundering anyway, and if I start diverging into fraud, … Continue reading →

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