Author Archives: ihatemoneylaundering

Latest leak lessons

Posted on September 23, 2020

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”.  I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading →

Posted in AML, Money laundering, White collar crime | Tagged , , , , , , , , , , , , , , , , , , | 4 Comments

Sixth sense

Posted on September 16, 2020

Right, here’s a little quiz for you: as of today, it’s 78 days until what?  Points deducted if you simply say, “Thursday 3 December” – although points added if you know that that’s my mother-in-law’s birthday [note to self: remind … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , | 6 Comments

AML for the autodidact

Posted on September 9, 2020

I’m a big fan of surveys and reports: give me a sniff of a group of compliance types being asked for their take on AML, and I’m there with my hand in the air, begging for the results, like the … Continue reading →

Posted in AML, Training | Tagged , , , , , , , , | 5 Comments

Osh Ghosh begone

Posted on September 2, 2020

I have had no legal training, but on the plus side I have a high boredom threshold and I love reading – both of which are, I believe, essential for lawyers.  This means that I can generally work my way … Continue reading →

Posted in Legislation, White collar crime | Tagged , , , , , , , , , , | 5 Comments

Is that why it’s called a PEP rally?

Posted on August 26, 2020

I am of An Age where every working surface in our house has been equipped with a cheap pair of reading glasses – who knows when I will need to read that care label, cooking instruction or baffling piece of … Continue reading →

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

Happy holidays!

Posted on August 19, 2020

Well hello everyone – I’m back.  And while I was away on my hols, I did wonder whether taking time off in the summer was the responsible thing to do.  As long ago as 1831, astronomer and statistician Adolphe Quetelet … Continue reading →

Posted in AML, Fraud, Money laundering, Organised crime | Tagged , , , , , , , | Leave a comment

A word to the wise

Posted on July 22, 2020

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

Posted on July 15, 2020

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

Posted on July 8, 2020

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

Posted on July 1, 2020

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