Category Archives: AML

A reliability rating for Regs

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

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It’s for you-hoo!

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

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Now and forever

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

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A fine fortnight

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

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From little acorns

I work regularly in the UK and four UK-related jurisdictions, and for those five I take pains to learn their AML legislation, regulation and guidance.  When it comes to the other jurisdictions of the world and their AML regimes, I … Continue reading

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A record number of records

I know I said last time that I wouldn’t be doing anything until the UK’s new Money Laundering Regulations 2017 and their attendant guidance notes are finalised and approved (we’re working towards 26 June 2017), but that doesn’t stop me having … Continue reading

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A state of grace

Someone asked me recently about grace.  Not the spiritual kind, or indeed the physical – if there is a loose paving stone within a hundred yards, I will trip over it.  No, what they were concerned about is the period … Continue reading

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Smile: you’re on ATM camera!

Years ago, I used to joke in AML training sessions that one day CDD would be obsolete because as soon as a baby was born s/he would be tattooed with an indelible barcode which would be used as proof of … Continue reading

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Conspiring against criminal cash

I have written a few times before about the interesting stage that all countries go through as their criminals (alongside ordinary people, but I’m less interested in them) transition from cash to non-cash working patterns.  As a jurisdiction’s AML regime … Continue reading

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The AML rank and file

So here we are, with the final piece of analysis of our AML survey.  The last question was the most complicated: I asked “There are various things that could be done to change the way we approach AML (in principle, … Continue reading

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