Monthly Archives: October 2015

Beware the EU shortcut

When MLROs are populating their lists of high- and low-risk jurisdictions, they are advised to consult as wide a range of (reputable) sources as possible.  (For non-MLRO readers, the risk status of a jurisdiction matters because if it is judged … Continue reading

Posted in AML, Bribery and corruption | Tagged , , , , , , | 4 Comments

Crime ain’t what it used to be

Recently the UK government published its first AML National Risk Assessment.  In its introductory look at the UK crime sector, it observes that “the number of armed robberies at banks and buildings societies has declined in the last decade” while … Continue reading

Posted in Money laundering, Organised crime | Tagged , , , , , , | 2 Comments

A superabundance of supervisors

With all eyes on the Fourth Money Laundering Directive, I will confess that I had lost track of the UK’s AML/CFT National Risk Assessment – and then it appeared last week.  There’s plenty of meat in it and it’s perfectly … Continue reading

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

Getting in a state about agents

When it comes to AML, I’m an equal opportunities preacher: I’ll tell anyone what to do.  So I take my AML hectoring, sorry, training into all manner of places, from swanky banks to glitzy casinos.  But the two parts of … Continue reading

Posted in AML, Legislation | Tagged , , , , , , | 7 Comments

More care for the spare

Even the most dedicated and determined MLRO needs a break from his work occasionally, and as he packs his flip-flops/salopettes* and the latest thriller/romance/colouring-in book* [* delete as appropriate] he can relax knowing that all is being left in the … Continue reading

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

Sometimes a dog deserves its bad name

I try not to subscribe to stereotypes, as they encourage laziness and shortcut thinking (or lack of thinking), but sometimes the subject of a stereotype seems to be doing all it can to perpetuate it.  We all remember James Ibori, … Continue reading

Posted in Bribery and corruption, Money laundering | Tagged , , , , , , , , , | Leave a comment

Regulatory arbitrage

No, that’s not the name of a minor – probably dastardly – character in a Mills and Boon novel: it is what happens when differing standards of regulation allow criminals to wriggle their way through the system by exploiting those … Continue reading

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , | 4 Comments

Novelty or naughty?

At an MLRO workshop in Guernsey last week (terrific day – still recovering my voice after all that AML chat) one of the MLROs came up to me during a break and asked whether I had seen this website, Continue reading

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

Treating the fairer sex more fairly

De-risking is a hot topic at the moment, with people agonising over how to marry appropriate and proportionate due diligence with profit, and how to protect the financial sector from the baddies without putting it beyond the reach of ordinary … Continue reading

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