Monthly Archives: July 2020

A word to the wise

MLROs and compliance folk are creatures of precision.  I (proudly) count myself among them, and I know that when I am designing procedures or assembling training materials or writing this blog, I make sure that I check my sources very … Continue reading

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Friends in low places

For my sins, I start every working day with a trawl of the latest money laundering stories.  As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading

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

Performance negated pay

Much has been written in recent weeks about the pandemic’s impact on AML endeavours – how to conduct CDD checks on clients who cannot leave their homes, and whether to accelerate acceptance of online CDD documents (is the risk of … Continue reading

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Nose in, fingers out

Recently a client asked me how to deal with difficult directors.  How to train them, you mean? I asked – how to encourage them to attend AML training and take note of our pearls of wisdom?  No, she said: I … Continue reading

Posted in AML, General thoughts | Tagged , , , , , | 2 Comments