Monthly Archives: December 2014

Ho ho high risk!

While casting around for an idea for this final blog post before Christmas (as you know, money laundering is something of a passion of mine, but even I have to admit that it’s not what you would call festive…), I … Continue reading

Posted in AML, Due diligence | Tagged , , , , | 6 Comments

I look down on him…

Earlier this month, the UK’s FIU, the National Crime Agency, published its “SARs Annual Report 2014”.  It has some SAR statistics and a few brief case studies, which are all useful for training, but I was keen to see how … Continue reading

Posted in Due diligence, Money laundering | Tagged , , , , , , , , , | 2 Comments

Fare’s fair

Any UK reader who has gasped in horror while handing over (metaphorical) fistfuls of cash to their railway company will remember the outrage we all felt when, in April 2014, it was revealed that a “City financier” had been cheating … Continue reading

Posted in Due diligence | Tagged , , , , , , , | 6 Comments

The piggy popularity poll

As we approach the end of the year, I always take the time to review my year – specifically, which of my projects and initiatives have worked, and which have not.  This year, for instance, my workshops for experienced MLROs … Continue reading

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The casino duck

I am doing some work with a casino, and they have introduced me to a term I had not heard before – much-beloved of the UK’s Gambling Commission, it turns out – which is “criminal spend”.  It means “the use … Continue reading

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

Just how close is close?

PEPs are a perennial and perplexing problem.  Who they are, how long they stay like that for, and what to do about them anyway – headaches all along the line.  But one aspect of PEPitude that has been exercising (perhaps … Continue reading

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Because you’re worth it

Are you sitting comfortably?  I ask only because I’m doing that scene-setting stuff again, and it’s going to take a while.  When I was a little girl, my grandma took delivery of a new three-piece suite.  It was an event … Continue reading

Posted in AML, Due diligence, Money laundering | Tagged , , , , , | 6 Comments

The wretched refuse of your teeming shore

When I was a little girl, I had one of those 3D plastic viewers; you put a circular cardboard plate of tiny transparencies in it, looked to the light, and pressed the trigger to change the picture.  Whenever he went … Continue reading

Posted in AML, Due diligence, Money laundering | Tagged , , , , , | 5 Comments