Systems to manual

I have a confession: I love writing AML manuals.  I know, I know – it’s akin to saying that for Sunday lunch I enjoy a nice roast kitten with puppy gravy, but there it is.  Who knows when it started, but I have always relished gathering information, sorting it into a logical order, and then determining the best way in which to communicate it.  Add my Favourite Subject Ever, and I’m in clover.  Rather marvellously, clients do occasionally ask me to redraft their AML manuals; they raise the subject almost apologetically, but I’ve got Word open and a skeleton table of contents in place before they’ve hung up.  But, dear readers, I do see some shockers.

The worst – and most common – mistake that MLROs make with their AML manuals is taking shortcuts.  When something changes, they make the minimum number of edits that they think they can get away with – which means, invariably, that bits are missed.  I know it sounds dull (actually, it doesn’t – but that’s my problem and not yours) but when you change any part of a document you must re-read the whole thing to make sure it still works.  Every single page.  Otherwise contradictions and omissions will creep in (can an omission creep in, or does it slink out?).

Another regular bugbear is inconsistency.  You call it KYC in one chapter and CDD in another.  They’re “high risk clients” in this table and “High-Risk Customers” in that one.  It sounds nit-picking (and what’s wrong with that?) but inconsistencies will lead to uncertainty and misinterpretation.  It’s worth remembering that very few of your staff, no matter what they tell you to the contrary when they sign their form, will read the AML manual from cover to cover.  They will turn to it in extremis, when they need to find reliable and unambiguous information quickly.

And tied to inconsistency is style.  I love a good, wide, illuminating, fascinating range of adjectives as much as the next person.  But the AML manual is not the place to practise your Booker-worthy prose.  Keep it clear.  Keep it repetitive.  If you mean “certified copies of all CDD documents must be obtained and kept on the client file”, don’t say, in the next chapter, “obtain certified copies of the documents” – just repeat exactly the same phrase to make it clear that the standard is unchanging.  Keep it clear.  Keep it repetitive.

It’s been attributed to almost everyone, from Thomas Hood to Nathaniel Hawthorne, Lord Byron and Maya Angelou, but the maxim remains true: easy reading comes from hard writing.  And it’s the responsibility of the MLRO to make sure that the AML manual is very easy reading.

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Loophole in the wall

Cash is a problem during a pandemic.  Cash-intensive businesses like nail bars cannot trade, and takeaway food outlets have turned into delivery hubs with payment in advance by card.  Luckily, anyone desperate to offload their criminal cash has a new-ish option that has been steadily gaining ground.  The cryptocurrency ATM is a freestanding machine that is appearing in the corner of shops, petrol stations and (I’m reliably informed by the Daily Telegraph newspaper) strip clubs, and it will happily swap your cash for cryptocurrencies and vice versa.

The CATM (no-one else calls them that – it’s my own invention and you’re welcome) was something of a novelty when a Robocoin machine opened in the Waves coffee shop in Vancouver in Canada in October 2013.  Europe got its first one two months later, in Bratislava in Slovakia.  CATMs come in two flavours: uni-directional ones allow you to buy cryptocurrency using cash or a debit card, while bi-directional ones allow you sell cryptocurrency as well.  Now you know what a dinosaur I am when it comes to matters cryptocurrency, so you will forgive me for quoting from the admirably clear description in Wikipedia: “[CATMs] look like traditional ATMs, but do not connect to a bank account and instead connect the user directly to a [cryptocurrency] wallet or exchange.  While some [CATMs] are traditional ATMs with revamped software, they do not require a bank account or debit card.  On average, transaction fees are 10-20% but can go as high as 25% and as low as 7%.”

As eny fule no, Bitcoin is having a moment – its value is surging.  And it’s dragging the CATM trend with it.  According to Coin ATM Radar, in February 2020 there were 6,759 CATMs in the world – and today there are 17,868.  Speaking to the Daily Telegraph, Ben Phillips of RockItCoin said that his company now has 900 CATMs installed in the US: “It just appears that more people are using Bitcoin for the first time and obviously more people are continuing to come back and use the machines.  We do add that element of privacy where users can feel secure, like they’re dealing just with us.  They’re not putting any bank information in.”

Whoa there, missy – did you say “adding an element of privacy”?  So people can feed stacks of cash into the CATM and get cryptocurrency added to their e-wallet, all without any pesky financial information being checked?  With the recent publicity about the dangers of – and to – money mules, this is surely a risk area that must be addressed.  Thankfully the regulator has CATMs in its sights: in a speech on 24 March 2021, Mark Steward, (Executive Director of Enforcement and Market Oversight at the FCA) announced that “we have now developed a version of the Warning List, called the Unregistered Cryptocurrency Businesses List, to help consumers and FCA authorised firms identify cryptocurrency firms that appear to be carrying on business in the UK but are not registered with the FCA or sought such registration – we placed the first names on the Unregistered Cryptocurrency Businesses List earlier this month, all crypto ATM firms”.  Sadly, CATMs are also on the criminal radar: at the end of last month, a man in Sydney was jailed for laundering money through CATMs – in this case, money was stolen from people’s cryptocurrency wallets and he then withdrew it in cash via CATMs.  So when lockdown lifts and you return once more to The Saucy Minx Exotic Dancing and Dining Club for Discerning Gentlemen and spot a new CATM in the corner, the strippers might not be the only ones losing their shirts.

Thanks to David Winch for pointing out this issue to me – I do love an AML issue

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Faint at art

It’s a tricky thing, art.  No – I don’t mean those arguments over whether an unmade bed or a black painted square is art, but the deliberations about when the art world is part of the AML community and when it isn’t.  Before the advent of the Fifth Money Laundering Directive, an art auction house or similar would be subject to the AML requirements (at least in the UK and other jurisdictions with EU-derived AML regimes) only as part of the “high value dealer” category.  And the definition of a high value dealer comes from the previous Directive, MLD4: “other persons trading in goods to the extent that payments are made or received in cash in an amount of €10,000 or more, whether the transaction is carried out in a single operation or in several operations which appear to be linked”.  In short, the key characteristic was the acceptance of large amounts of cash – actual folding (or clinking) cash.

MLD5 moved the goalposts, and many involved in the trade in art found themselves ejected from their cosy home with the HVDs and lodged in a new category of their own, with the requirements of MLD5 now additionally applying to “persons trading or acting as intermediaries in the trade of works of art, including when this is carried out by art galleries and auction houses, where the value of the transaction or a series of linked transactions amounts to €10,000 or more; [and] persons storing, trading or acting as intermediaries in the trade of works of art when this is carried out by free ports, where the value of the transaction or a series of linked transactions amounts to €10,000 or more”.  In other words, although the €10,000 threshold remains, the form of payment – cash or otherwise – is immaterial.  So any art market participants who had managed to exclude themselves from the AML requirements by refusing to accept cash are now back in.

Perhaps understandably, there has been some confusion about who is included – overlaid by the inevitable reluctance to accept their fate.  And some leeway has been permitted in these troubled times.  But the art sector is now in the spotlight.  On about 19 March 2021 the National Crime Agency issued one of its occasional “amber alerts”, the time to art dealers.  I can’t unearth the actual document on the NCA website [if you can, please post the link in a comment – I’d love to find it], but a report on it in the Evening Standard quotes Graeme Biggar (DG of the NCA’s National Economic Crime Centre) as saying that although they have been encouraged to file more SARs, there has been an inadequate response from dealers, despite their sector being “a relatively high risk area for money laundering because it is a market used to operating with anonymity, where they use third parties, and where the source of the funds is often not clear”.  He also comments that “HMRC will be looking a bit harder too at art dealers”.  Let’s hope the art sector is finally getting the picture.

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The young and the riskless

I never thought I’d say this, but there are two great advantages to being 55: (a) I’ve had my first covid jab (one shivery night afterwards but apart from that – woohoo!), and (b) I’m not being targeted quite as doggedly by fraudsters or aggressive sales tactics.  Youngsters, however, are paying the price for their porcelain complexions and silent knee joints by having to be ever more vigilant against such approaches.

Earlier this month, fraud prevention service Cifas confirmed that more than 40% of the more than 17,000 cases of money muling in 2020 involved victims aged 21 to 30 – leading the media to dub them “generation Covid”.  According to Cifas, “with thousands [of young people] facing job losses as a result of the pandemic and graduates entering the jobs market at a time of unprecedented uncertainty… criminals are exploiting people’s financial difficulties by using social media platforms, jobs websites and phishing emails to approach them with offers of easy cash”.

Last week a friend contacted me to say that her daughter – aged 20 – had narrowly escaped “financial meltdown”.  Daughter had received a text purportedly from Royal Mail, claiming that a parcel was waiting to be delivered to her but she needed to click on a link to pay the £2.99 settlement.  Now, daughter is engaged in online shopping 23½ hours a day and employs a postman pretty much full-time so this did not seem unusual to her – the only thing that concerned her was the word “settlement”, which she asked her mum about.  Mum was suspicious and unearthed the warning from the trading standards people.  We’re all old and cynical, and know how the postal system works, but with customs changes post-Brexit and general pandemic shenanigans, even the savviest of us can be tricked.  Now there’s a jolly slogan: just don’t click – it might be a trick!

And yesterday the Financial Conduct Authority issued the results of research it commissioned into “Understanding self-directed investors”.  What caught my eye was the FCA warning that “younger investors are taking on big financial risks”: “There is a new, younger, more diverse group of consumers getting involved in higher risk investments, potentially prompted in part by the accessibility offered by new investment apps.  However, there is evidence that these higher risk products may not always be suitable for these consumers’ needs as nearly two thirds (59%) claim that a significant investment loss would have a fundamental impact on their current or future lifestyle.”  In other words, they’re staking what they can’t afford to lose.

But even the investor who is longer in the tooth displays a worrying lack of awareness.  The word “risk” runs through the bones of every MLRO like Blackpool through a stick of rock.  But the FCA’s research reveals that “there is a striking lack of awareness and/or genuine belief in the risk of investing, with over four in ten (45%) [respondents] not viewing ‘losing some money’ as a potential risk of investing – despite the presence of disclaimer warnings”.  They then turn a second blind eye to danger: “Additionally, most have high confidence in their abilities to identify scams and fraud, although in reality strategies largely rely on an investment opportunity ‘not feeling right’ or looking unprofessional” – despite some confessing to having fallen for scams that looked perfectly professional.  Add to this the boredom that comes with being stuck at home during lockdown, the speed with which investment “buzz” can be generated on social media, and the spare money that some people have now that they can’t go out or on holiday, and it’s prime time for fraudsters.

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Mind your own business

One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators.  Although this can be done, it takes a stern resolve, a stiff spine and a clear understanding of just who is entitled to just what.  And one of the regular points of conflict is the sharing of information about SARs with the Board.

Some MLROs – notably, those working within FCA-regulated firms – are required to make an annual report to their Board, and most MLROs of my acquaintance (regardless of their sector or jurisdiction) choose to do this.  Part of any MLRO annual report to the Board is going to be information about SARs – number of internal reports received and number of external disclosures made (which gives a conversion rate), and observations about any discernible patterns (e.g. the majority of reports are made by one member of staff in the take-on team, or no-one in the Birmingham office has even made a report, or a growing proportion of reports feature clients who are PEPs).  Looking at it from the other side, Boards are required to make sure that they are conducting sufficient oversight of their firm’s AML/CFT regime, which will include checking that the reporting/disclosing system is working well.  Where the conflict arises is when the Board demands to know more than the MLRO wishes – or is permitted – to say.  Directors will sometimes want to see specific SARs, or will ask for the names of clients reported to the FIU.  And this type of request triggers the “tipping off klaxon” with which all MLROs are fitted on appointment (a painless but necessary procedure).

Thankfully, this conflict is increasingly being recognised by regulators and by FIUs, and MLROs are being offered more guidance on just what they can and cannot (or should and should not) share – which gives them something to show their Board to explain their course of action.  For instance, the JMLSG in the UK has produced a template for the MLRO’s annual report, which, in the section on reporting, suggests the following content:

  • Internal reporting
    • Summarise the number of internal reports made by business area. Distinguish between the number of reports picked up by central monitoring units and staff.
    • Number of ‘false positives’ generated where internal reports were not forwarded to [the FIU]. Whether this has increased or decreased since the last report.
    • Summarise the circumstances that may have led to increased/decreased reporting and consider any significant trends in reporting.
    • Summarise any quality checks that are made by the Nominated Officer in the area of reporting.
  • External reporting
    • Note whether there have been any money laundering cases that have arisen where reports have not been made.
    • Provide a breakdown by business area of reports passed on to [the FIU], and the number of reports that have not been made.
    • Consider any significant trends in reporting that might require the Nominated Officer to change system parameters for suspicious transaction reporting. Indicate whether such changes have been actioned or are requested.
    • Any feedback from [the FIU] on reporting, individually or by sector.

This makes it clear that the MLRO should be sharing anonymised, general information with the Board, post facto – and the Board should not expect to receive identifying information (about either reporting individuals or reported-on clients), and certainly should not expect to be involved in reviewing or (heaven forfend) approving the submission of SARs.  Some MLROs – particularly those new to the job, or those working with particularly dominant directors – might feel obliged to share more than is necessary, or indeed safe.  To them I say bon courage – the law is on your side.

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Hang on every word

I have been called pedantic, but that’s not strictly accurate.  The fact is that I make my living from – and spend much of my leisure time with – words.  Most compliance-y people are good at detail: at school we were the ones who always did what the teacher said (“Read all the way through all the questions before starting”) and as working people we’re the ones who fill in all the forms fully and correctly.  Moreover, we know the importance of words.  Precise and specific words.  This matters greatly when wrestling with legislation and when dealing with regulators.

Let’s take a look at legislation first.  I’m in the UK, so I will refer to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, but feel free to grab your own domestic AML legislation to play along.  I’m turning, feverishly, to Regulation 28, which sets our “Customer due diligence measures”, and it says this: “The relevant person must – (a) identify the customer… (b) verify the customer’s identity…; and (c) assess, and where appropriate obtain information on, the purpose and intended nature of the business relationship or occasional transaction.”  Later on, in Regulation 35, and with reference to PEPs and EDD, it says this: “A relevant person [with a PEP client] must… take adequate measures to establish the source of wealth and source of funds which are involved in the proposed business relationship or transactions with that person.”  Can you see those words?  We have “identify”, “verify”, “assess”, “obtain information on” and “establish”.  I’m not going to go into a great dissection of their specific meaning (that’s for training, not a blog post), but it’s important simply to see that they are different.  The people who drafted and approved the legislation chose them carefully (assessment is not verification, and obtaining information is not establishing), and we must obey them.

And now let’s have a little think about regulator-speak.  As you almost certainly know, you can open any AML/CFT guidance – take your pick from at least half a dozen versions in the UK – and you will soon spy three levels of obligation: must, should and could/may/might.  If something is expressed using the word “must”, you as MLRO have no choice: it’s either straight from the legislation (and not doing it is a criminal offence) or it’s a regulatory obligation (and not doing it puts you at risk of losing your licence).  If something is couched in the woolly words – could, may, might – then it’s up to you: it’s a suggestion, but if you have a preferred alternative, then so be it.  But it’s the middle one that catches people out: the “should”.  If a regulator says that you “should” do something, the expectation is that you will do it and if you don’t, you will explain clearly why you have not done it – conform or confirm, if you will.  Too many firms think that “should” and “could” are equivalent – it’s a dangerous stance.  And I have chosen that word carefully.

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Chewing the FATF

Last week the FATF met for its regular plenary meeting and – as it does three times a year – updated its list of what I call “dodgy countries”, which are more correctly known as “jurisdictions under increased monitoring”.  In the interests of frankness, I should explain that I call lots of jurisdictions dodgy – they get the label if they have high levels of corruption or money laundering or terrorist financing, or if their pursuit of money laundering is lukewarm, or if (as is the case with the FATF list) they have an AML/CFT regime that is not yet up to snuff.  Quite rightly – given the independence and staying power of the FATF – its list is highly regarded, and this time round they suggested that Burkina Faso, the Cayman Islands, Morocco and Senegal could bear closer monitoring of their AML/CFT regimes.  But does it matter?  After all, the FATF has no legal or regulatory powers at its disposal: it can’t fine jurisdictions, or bar them from international business.  All it can do is recommend that its members take certain action regarding the listed jurisdictions – and it can’t even compel its members to do that.

Of course, I think that it does matter – and so does the FATF, otherwise it wouldn’t bother.  Most jurisdictions – and cascading from them, most regulators and most MLROs – use the FATF list as shorthand: the FATF’s work is so detailed and thorough, with its Forty Recommendations, its technical compliance and effectiveness ratings, and its 330+-page mutual evaluation reports, that it would be foolish not to take its conclusions seriously.  And with 32 years of experience, the FATF knows what it’s about – what a good AML/CFT regime looks like and how it works.  Yes, there might be some regional favouritism, akin to the block voting in the Eurovision Song Contest (according to Eurovision expert William Lee Adams of Wiwibloggs, Russia can count on its former Soviet nations to such an extent that “it could show up without a song and still make the final”).  Yes, you might look at the provenance of some of the evaluators and wonder whether they have their own axe to grind.  And yes, it is annoying that the reports are always at least a year out of date by the time they’re published.  But could you do any better?

And so the AML world waits on tenterhooks for the thrice-yearly pronouncement.  And although those who are listed will froth and bluster and say they’ve been misunderstood or misrepresented, they have to take it on the chin.  The local press in the Cayman Islands pinpointed exactly why: “While not as severe as the FATF’s blacklist… being placed on the grey list is still a reputational blow for the Cayman Islands [because the FATF] encourages its members to take the noted deficiencies into account in their risk analysis.  Cayman will now have to work on implementing an agreed action plan within the next 15 months under the monitoring of the FATF and the Caribbean FATF.”  For the time-poor MLRO (is there any other kind?), the FATF list regularly fills and updates a column in his list of high-risk jurisdictions – and gives him an opportunity to remind staff and directors of the importance of keeping AML efforts current with the correct application of EDD.

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Back to school

When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day spent sliding down the Malvern Hills on a tea-tray pinched from the school kitchen.  I also remember having to queue up on Sunday evening for our housemistress to dole out our pocket money: she had an enormous ledger and we had to sign against our name to show we’d had the dough.  It seems that not all public schools are as diligent when it comes to monitoring transactions.

I’ve been banging this drum for a couple of years now, suggesting that the private education sector should be encouraged, if not compelled, to pay more attention to source of funds.  I’m not the only one to see the possibilities; in October 2019 Transparency International published a terrific report titled “At Your Service: Investigating how UK businesses and institutions help corrupt individuals and regimes launder their money and reputations”, and in that they warned that “prestigious UK educational institutions are a key pull factor that brings corrupt individuals and their families to the UK”.

In October 2014, allegations surfaced that Millfield School in Somerset had received payments as part of the “Russian Laundromat” via which wealthy Russians were getting their loot away from Kremlin control.  One of the companies uncovered during an investigation into the laundromat was Valemont Properties Limited, registered in the UK.  In September 2011 Millfield sent Russian businessman Vadim Zadorozhny a bill for £10,943 for the education of his son – and the bill was settled by Valemont Properties Limited.

And now the UK’s National Crime Agency has published an “amber alert” titled “Bribery & Corruption Risks to UK Independent Schools: Case Studies and Red Flags”.  The alert is written for banks, legal and accountancy professionals – and the independent school sector itself.  With its examples of how laundering can be done, and red flags to consider, it’s a lesson for us all.

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I beg your pardon

In the last few days of the presidency of Donald Trump, when he was granting pardons to his chums and executing three black men and a woman while his mob was looting the Capitol, I read a tweet that has stayed with me.  I can’t remember who wrote it, or if they were quoting someone better known, but it said this: “If you want to know whether you are on the right side of an argument, look at who is standing next to you.”  This has caused me a fair bit of soul-searching in relation to a couple of stories.

Back in November 2006, Glaswegian publican and restaurateur David Martindale was jailed for 6½ years for drug offences and money laundering.  While in jail he started working on a university course, and when he was released in 2010 he continued and was awarded a degree in construction management.  Once a promising young footballer, he started coaching and eventually found his way to Scottish Premiership club Livingston.  And on 26 January 2021 he was deemed a fit and proper person to work as the club’s manager – a test he had failed before.

In 2003, Shadab Ahmed Khan set up his own law firm and was named professional of the year at the Yorkshire Asian Business Convention.  In 2007, after being found guilty of money laundering, by conducting conveyancing for properties worth £593,000 for convicted drug dealer Khalid Malik, he was jailed for four years.  He was struck off by the Solicitors Disciplinary Tribunal in 2011, after he was found to have acted with a lack of integrity, but not dishonesty.  And a couple of weeks ago he was readmitted to the roll by the SDT after they found that he had been “totally rehabilitated”.  The move was opposed by the Solicitors Regulation Authority, which said that “limited evidence of recent rehabilitation” had to be balanced against Khan’s conviction for “serious offences involving money laundering in relation to drug dealing”.  The SDT imposed conditions on his practising certificate, preventing him from being a sole practitioner, a partner or manager of a law firm, a COLP or COFA or holding client money.

Now here’s my confession.  In all other aspects of my life, I am a strong believer in second chances and in rehabilitation.  The point of the criminal justice system must be to punish, of course, but also to repair and re-direct.  I make a point of patronising businesses, like Timpson’s, that employ ex-offenders.  But when it comes to money laundering, I can feel myself getting ready to throw away the key.  So I think I need to chill.  Yes, I hate money laundering – see, it’s written up there, right across the top of this page.  But I shouldn’t hate the money launderer – and the more of them that we can steer back onto the path of righteousness (like David Martindale, and Jerome Mayne, and the Fraudster behind the Diary), warning others of the dangers, the better.

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Name and shame

We’re all used to lists and databases.  There are sanctions screening systems and PEP screening systems.  Within their organisations, MLROs have access to client databases.  And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership and setting up searchable registers.  What all of these have in common is names: you put in the name of a client and see what comes back.  If nothing comes back and you’re smart, you try a slightly different spelling, or put the name in a different order (you’ve heard before about my friend Simon Anthony and how he’s regularly recorded as Mr Simon).  But it seems that some sneaky individuals are simply sidestepping the whole “being on a list” thang by changing their names.

Now that I’ve heard of it, it seems the most natural reaction in the world.  But I had assumed that there would be some way of tracking through from the original name to the new one, that would make the change more of a personal preference than a successful attempt to disappear from view.  And then on 20 January 2021 we read that Raimbek Matraimov, former deputy chief of Kyrgyzstan’s Customs Service, had changed his surname after being placed on the US Magnitsky sanctions list for his alleged involvement in the illegal funnelling of hundreds of millions of dollars abroad.  How could this work, you might ask?  After all, when someone’s name changes through marriage or divorce – or wanting to be a squiggle rather than a Prince – their financial institutions will insist on seeing proof of the official change from one to the other.  But Damira Azimbaeva of the state registration service of Kyrgyzstan confirmed that both Matraimov and his wife Uulkan Turgunova had changed their surnames – and that she would not be sharing their new surnames because of data confidentiality.  Thankfully, the couple have also been embroiled in a libel lawsuit, and to clarify things the judge in that case helpfully announced that Matraimov had changed his last name to Ismailov, and his wife had changed her surname to Sulaimanova.  (So the names you’re after are Raimbek Ismailov and Uulkan Sulaimanova.  For now at least.)  Another judge, Klara Sooronkulova, told the media she believed that Matraimov and his wife had changed their names specifically to avoid sanctions: “I think after being placed under the Magnitsky Act, many doors around the world will be closed for them.  Many problems may now arise for them to keep their property under their ownership.”  I jolly well hope so.

So that’s yet another question for the MLRO to ask clients (along with “is this your only nationality?”): “Have you ever changed your name, and what was it before?”.  When I was a girl I dreamed of being Mrs Victoria Osmond – Victoria because it was my favourite name, and Osmond because of the warbling toothsome one and “Puppy Love”.  So if things ever get too hot for me in the world of AML, you know who I’ll be next.

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