Author Archives: ihatemoneylaundering

Systems to manual

Posted on April 14, 2021 by ihatemoneylaundering

I have a confession: I love writing AML manuals.  I know, I know – it’s akin to saying that for Sunday lunch I enjoy a nice roast kitten with puppy gravy, but there it is.  Who knows when it started, … Continue reading →

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Loophole in the wall

Posted on April 7, 2021 by ihatemoneylaundering

Cash is a problem during a pandemic.  Cash-intensive businesses like nail bars cannot trade, and takeaway food outlets have turned into delivery hubs with payment in advance by card.  Luckily, anyone desperate to offload their criminal cash has a new-ish … Continue reading →

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Faint at art

Posted on March 31, 2021 by ihatemoneylaundering

It’s a tricky thing, art.  No – I don’t mean those arguments over whether an unmade bed or a black painted square is art, but the deliberations about when the art world is part of the AML community and when … Continue reading →

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The young and the riskless

Posted on March 24, 2021 by ihatemoneylaundering

I never thought I’d say this, but there are two great advantages to being 55: (a) I’ve had my first covid jab (one shivery night afterwards but apart from that – woohoo!), and (b) I’m not being targeted quite as … Continue reading →

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Mind your own business

Posted on March 17, 2021 by ihatemoneylaundering

One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators.  Although this can … Continue reading →

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Hang on every word

Posted on March 10, 2021 by ihatemoneylaundering

I have been called pedantic, but that’s not strictly accurate.  The fact is that I make my living from – and spend much of my leisure time with – words.  Most compliance-y people are good at detail: at school we … Continue reading →

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Chewing the FATF

Posted on March 3, 2021 by ihatemoneylaundering

Last week the FATF met for its regular plenary meeting and – as it does three times a year – updated its list of what I call “dodgy countries”, which are more correctly known as “jurisdictions under increased monitoring”.  In … Continue reading →

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Back to school

Posted on February 24, 2021 by ihatemoneylaundering

When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day … Continue reading →

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I beg your pardon

Posted on February 17, 2021 by ihatemoneylaundering

In the last few days of the presidency of Donald Trump, when he was granting pardons to his chums and executing three black men and a woman while his mob was looting the Capitol, I read a tweet that has … Continue reading →

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Name and shame

Posted on February 10, 2021 by ihatemoneylaundering

We’re all used to lists and databases.  There are sanctions screening systems and PEP screening systems.  Within their organisations, MLROs have access to client databases.  And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership … Continue reading →

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