Monthly Archives: June 2015

Taking the criminal temperature

Every year, the UK’s National Crime Agency puts out a “National Strategic Assessment of Serious and Organised Crime”, which I use as a very handy criminal barometer to measure what professional criminals are spending their time on.  The 2015 edition … Continue reading

Posted in Money laundering, Publications | Tagged , , , , , , , , , | 8 Comments

Cramped corporate quarters

Like many of you, I am sure, my interest was piqued last week by the story that broke on the Beeb (or at least that’s where I first heard it) about shell companies in Scotland allegedly being used to launder … Continue reading

Posted in AML, Money laundering | Tagged , , , , , , , | 10 Comments

Making an ass of your DD

I’m not a big fan of motivational observations like “there’s no i in team” or  “believe you can and you’re halfway there”, particularly when they’re superimposed on soft-focus photos of dolphins or sunsets or dolphins in the sunset for extra … Continue reading

Posted in AML, Due diligence | Tagged , , , , , , , | 4 Comments

It’s the taking part that counts

We’ve all been rather obsessed with the Fourth Money Laundering Directive.  Well, we have in my house.  Well, I have – the cat’s not that bothered.  And as a result the UK’s new Serious Crime Act 2015 has slipped into … Continue reading

Posted in Legislation, Organised crime, Uncategorized | Tagged , , , , , , | 6 Comments

Tales of the unexplained

“When did you stop beating your wife?”  Famous as the question to which there is no right answer, this is now joined by “Don’t you support civil liberties?”.  Of course we all agree that there should be civil liberties, but … Continue reading

Posted in Bribery and corruption, Money laundering | Tagged , , , , , , , , , | 4 Comments

A directive date for 2017

It feels as though we’ve been waiting for the Fourth Money Laundering Directive for about a decade, doesn’t it?  Well, I suppose we have, really, as the third one was adopted in 2005.  But at long last we know what’s … Continue reading

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Cash will do nicely, sir

Remember the days of “cash is king”?  It may still be handy for getting a good deal on a second-hand car, but otherwise, for those of us in the AML community, cash is a pain in the proverbial.  The Fourth Money … Continue reading

Posted in AML, Money laundering | Tagged , , , , , , , | 3 Comments

Upgrading to a new model

I’ve been hearing from friends in Guernsey that a recent industry presentation there suggested that the familiar three-stage model of money laundering – placement, layering and integration – is out of date.  Granted, it dates from the mid-1980s, but then … Continue reading

Posted in Uncategorized | Tagged , , , , , , | 16 Comments

Cakes and liability

Apart from it being the first day of summer (and it’s still perishing), today heralds the coming into force of the part of the Serious Crime Act 2015 which amends section 338 of the Proceeds of Crime Act.  (I know, … Continue reading

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , | 2 Comments