Category Archives: AML

Levy-hearted

I have my fingers in my ears and am chanting “la la la” to myself, as I refuse to listen to any more corona-chatter.  For today’s blog I am going to pretend that nothing untoward is happening and have a … Continue reading

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

This time it’s personal

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading

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

Free for all

Just as Voldemort’s name cannot be used for fear of conjuring him up, so too we have declared a taboo in our house on the B word (the one to do with the EU) and on the name of the … Continue reading

Posted in AML, Bribery and corruption, Money laundering, Organised crime, Supervision, Tax | Tagged , , , , , , , , , , , , | 4 Comments

Regrets, he’s had a few

Here in the UK – and I am sure that many countries will have something similar – we have an organisation called the Restorative Justice Council.  The purpose of restorative justice, as explained on the RJC’s website, is “[to bring] … Continue reading

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , | 4 Comments

The sniff test

The relationship between jewellers and the AML regime is a complicated one.  For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of … Continue reading

Posted in Money laundering, AML | Tagged , , , , , , , , , | 9 Comments

Taking money laundering to ‘art

“I don’t know much about art, but I know what I like.”  That (very common) attitude might be OK when you’re standing in a gallery trying to make sense of something you’ve seen, but it won’t pass muster if you’re … Continue reading

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

Heading for the exit

One of my great ambitions – which I achieved for a short while in one jurisdiction – is to facilitate communication and foster understanding between the three sides of the AML triangle: regulator, law enforcement and industry.  Now, that’s a … Continue reading

Posted in AML, Money laundering, Regulation | Tagged , , , , , , , , , , , , | 4 Comments

The special joy of damage joy

I remember the first time I was told what schadenfreude means – pleasure derived from another’s misfortune.  I quickly realised what an essential component of life it is, and thought how odd it is that only the Germans have seen … Continue reading

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

A piggy new year to everyone

Welcome back, one and all.  Well, wasn’t that an exciting festive period?  Just as I was undoing the top button on my skirt, ready to launch into the yard of Jaffa Cakes that my husband (he knows me so well) … Continue reading

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

Take my word for it

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading

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