Monthly Archives: December 2018

Wimples and wagers

Posted on December 21, 2018 by ihatemoneylaundering

In recent AML training I have found myself talking more and more about the “CDD jigsaw”. As with all jigsaws, the CDD version involves gathering lots of little bits of information – some of which might seem indecipherable or unrelated … Continue reading →

Posted in AML, Money laundering | Tagged AML, casino, due diligence, financial crime, Gambling Commission, money laundering, proceeds of crime, source of funds, suspicion | 2 Comments

Just do the math

Posted on December 17, 2018 by ihatemoneylaundering

I am currently reading “How Not to Be Wrong” by American mathematician Jordan Ellenberg. Not that I am wrong very often, of course, but it pays to protect one’s elevated position. In truth, I scraped by in my maths A-level, … Continue reading →

Posted in Due diligence, Fraud, Money laundering, Organised crime | Tagged due diligence, financial crime, fraud, money laundering, organised crime, proceeds of crime, risk-based approach, suspicion, white collar crime | 2 Comments

New Guernsey piggies in the sty

Posted on December 13, 2018 by ihatemoneylaundering

A very quick post specifically for my Guernsey readers. Just for you, I have: Read the new Schedule 3 and Handbook cover to cover Updated all five of my piggy books – for NEDs, and for the accountancy, banking, fiduciary … Continue reading →

Posted in AML, Money laundering, Publications | Tagged Guernsey, Guernsey Financial Services Commission, guidance, money laundering, publications, training, writing | 3 Comments

The concept of anonymous publication

Posted on December 12, 2018 by ihatemoneylaundering

We all have a talent, and mine is words. I love reading and writing them, my spelling is pretty crash-hot, and if I am trying to remember something, I tend to see it as a word, e.g. “I’ve forgotten his … Continue reading →

Posted in AML, Money laundering, Supervision | Tagged AML, communication, disclosure, due diligence, FCA, Financial Conduct Authority, Gambling Commission, government, Guernsey Financial Services Commission, HMRC, ML Regulations, money laundering, publications | 4 Comments

Keeping up with the Joneses, les Dubois and die Schmidts

Posted on December 7, 2018 by ihatemoneylaundering

I mentioned in my previous post that Guernsey is on the cusp, nay, the very brink of getting new AML legislation. This represents the conclusion of their exercise to fall into line with the Fourth Money Laundering Directive (or as … Continue reading →

Posted in AML, Legislation | Tagged AML, directive, guidance, MLD4, MLD5, MLD6, money laundering, Money Laundering Directive, supervisor | Leave a comment

Chaos theory?

Posted on December 3, 2018 by ihatemoneylaundering

Regular readers will know that I do a lot of work in Guernsey, and that in general I am a supporter of that jurisdiction’s approach to AML. However, one issue on which we – Guernsey and I – have long … Continue reading →