Category Archives: Due diligence

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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Cloudy, with a chance of optimism

I’m not an early adopter, as you probably know: my blog came late to the game (started in 2011, although I hope I have made up for it since then with my doggedness), and my website is rather old-fashioned (I’m … Continue reading

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The law is just the law

For my next survey question, I moved into the realms of fantasy (or at least, I hope it’s fantasy – with Brexit, nothing’s certain any more): “If all the AML obligations were removed from legislation and regulation, what would you … Continue reading

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Power to the AML people

Now that I have whetted your appetites with that first course of participants in my little AML survey, let’s move on to the first meat course: why you do what you do.  The survey question was: “Being totally honest, please … Continue reading

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Sliding into EDD

And here is my third and (for the moment) final post on the UK’s draft new money laundering regulations.  One little phrase jumped out at me in the consultation document: “EDD is a sliding scale”.  The point is made in … Continue reading

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Hypocrisy and heavy-handedness

Since I left Sunday school with nary a backward glance when I was about eight, I have had little to do with organised religion.  I enjoyed daydreams about unattainable priests as much as the next teenage girls, but realised quite … Continue reading

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Do as I say

I’m going to do to you what is often done to me: I am going to tell you my own anti AML story.  Actually, it’s an anti anti AML story – you’ll see. In deference to the diktats of the … Continue reading

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Dabs and mince pies

Have you heard of Aadhar?  No, nor me.  The name comes from the Hindi for “foundation”, and it’s a cloud-based ID database that holds the details of (at last count) over a billion Indians.  When you register with Aadhar, you … Continue reading

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Goldilocks and guidance

As regular readers will know, I am most active in five jurisdictions: UK, Guernsey, Jersey, the Isle of Man and Gibraltar.  I can – and do – work in other places, but I feel most comfortable when I know the … Continue reading

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It pays to check

Last week I watched a programme called “What Britain Earns with Mary Portas”.  Although the title suggests that this was a limited look at the earnings of people who are in business with Mary Portas, it was in fact a … Continue reading

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