Author Archives: ihatemoneylaundering

Feeling the benefit

Posted on July 19, 2017

One of my very favourite things in my professional life is the concept of criminal benefit.  I like what this says about our attitude to crime and those who commit it.  Put very simply – and I am sure a … Continue reading →

Posted in Legislation, Money laundering | Tagged , , , , , , , | Leave a comment

Near-o tolerance

Posted on July 14, 2017

A recent article in the Economist made a very valid point about recent AML endeavours – that sometimes they can have unfortunate consequences.  I have blogged quite a bit about “de-risking”, or what the FATF calls “the wholesale cutting loose … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , | Leave a comment

Standing my AML ground

Posted on July 10, 2017

Money laundering and I – or rather, AML and I – have been on intimate terms for more than two decades now.  The muscle memory in my fingers is such that I cannot type the word “money” without following it … Continue reading →

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

Measuring the uncountable

Posted on July 5, 2017

One of the hardest aspects of any AML regime is measuring its effectiveness.  A bit like insurance, it’s trying to quantify what might have happened if you hadn’t had it.  (That sounds like a nightmare sentence from the translation paper … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , | 5 Comments

Yippee – more acronyms!

Posted on June 30, 2017

Last week I discovered that something that exercised me a great deal – the “once a PEP, always a PEP” stance of Guernsey, Jersey and the Isle of Man – did not seem to concern the MLROs in those jurisdictions … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , | 15 Comments

Thoroughly Modern Piggies

Posted on June 26, 2017

So tell me: what did you do this weekend?  Sit in the garden?  Sail to France?  Slap a few prawns on the barbie?  I did none of these: instead, I sat at my desk, surrounded by the new Money Laundering, … Continue reading →

Posted in AML, Legislation, Money laundering, Publications | Tagged , , , , , , , | 10 Comments

A reliability rating for Regs

Posted on June 21, 2017

I regularly visit Switzerland which, being such a lumpy little country, has a lot of weather – and many ways in which the weather can kill you (avalanches, mountain mists, tsunamis, etc.).  (I know you won’t believe me about the … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , | Leave a comment

It’s for you-hoo!

Posted on June 16, 2017

Apart from the days when I am out preaching the AML gospel, I work alone in an office above my garage.  Although this means that I get all the Jaffa Cakes and can break off to dance to ABBA’s “When … Continue reading →

Posted in AML, Training | Tagged , , , | 12 Comments

Now and forever

Posted on June 12, 2017

As regular readers will know, I have a great fondness for Guernsey.  It has a mild climate, lovely scenery, excellent food – and a rather admirable AML regime.  (That last bit doesn’t make it into the VisitGuernsey brochures or telly … Continue reading →

Posted in AML, Due diligence, Legislation | Tagged , , , , , , , , | 9 Comments

A fine fortnight

Posted on June 7, 2017

What else could I blog about today but the seemingly daily fines on financial institutions for AML failings?  Here’s what has happened (you can see the links to all of these stories on the Newsroom page of my website): 22 … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , | 1 Comment