Author Archives: ihatemoneylaundering

Wimples and wagers

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 , , , , , , , , | 2 Comments

Just do the math

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 , , , , , , , , | 2 Comments

New Guernsey piggies in the sty

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 , , , , , , | 3 Comments

The concept of anonymous publication

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 , , , , , , , , , , , , | 4 Comments

Keeping up with the Joneses, les Dubois and die Schmidts

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 , , , , , , , , | Leave a comment

Chaos theory?

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

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

The tarnish on golden visas

I have mentioned before the concept of “golden visas” and passports-for-sale.  In today’s politically uncertain world they are becoming ever more popular, and last month Transparency International published a report called “European Getaway: Inside the Murky World of Golden Visas”.  … Continue reading

Posted in AML, Due diligence, Legislation, Money laundering | Tagged , , , , , , , , , , , | 3 Comments

Something in the way she moves

A while ago I wrote about facial recognition software being used for client identification at ATMs and to apprehend scallywags out in public.  But of course technology does not stand still, and one of the shortcomings of facial recognition software … Continue reading

Posted in AML, Due diligence | Tagged , , , , , , , | 2 Comments

Interesting times

I like AML legislation as much as the next person – perhaps more, unless that person is an MLRO.  If there’s updated AML legislation on the horizon I really look forward to it, and I’ve been on tenterhooks for about … Continue reading

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

‘Dammed if you do

In a rather handy follow-on to my last blog post, which discussed my reasons for supporting the inclusion in the AML family of businesses that sell services for cash, Amsterdam’s administrative court has taken an interesting step.  A team of … Continue reading

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