Category Archives: AML

Friends in low places

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

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Performance negated pay

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

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

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Data doom and delight

With writing a post once a week only (I’ve fallen into writing longer posts less frequently – hope that’s OK), there’s sometimes a bit of a delay until I get round to dealing with something that’s been in the news.  … Continue reading

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A sprinkling of SAR-dust

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime.  Does it shift the burden of investigation from law enforcement to the financial sector?  Does it cost much more than it saves?  Are … Continue reading

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A most tempting offer

The name of my company is the result of a family joke: my father observed one day that I was always thinking about crime.  I wasn’t sure I’d be allowed to have the name but I was, and it’s memorable … Continue reading

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

Webinar woes

Like many of you, I am trying to ensure that I keep my skills and knowledge as current as I can.  I don’t have CPD obligations, but it’s easy to get stale or set in our ways, and there is … Continue reading

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Leak technique

I’ve been doing some remote training recently for a new MLRO, which has been great fun: we’ve covered all the essential and then plenty of those fun, tangential topics that concern MLROs – including beneficial ownership and (our topic for … Continue reading

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The new crimino-normal

Much as I try to ignore it – otherwise it absorbs our every waking moment, and some of our nightmares – I do occasionally find that there is an interesting nexus between the coronavirus and money laundering.  And this week … Continue reading

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Calculators at the ready

Sometimes words enter your vocabulary and you can’t remember where or when you first heard them but suddenly they’re there and you’re hearing and using them all the time.  I’m not talking about “lock-down” or “social distancing” or “flattening the … Continue reading

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