Category Archives: Due diligence

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

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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

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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

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Lights, camera, action!

After my little rant about podcasts, I can report this week that conversely I am fully in favour of what I still call video clips.  In the olden days, when I used videos as part of my AML training, we … Continue reading

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Copyright or copy wrong?

As an author, I am rather keen on the concept of copyright – the noun first being used in, we are told, 1729 to mean “the exclusive right to make and sell copies of an intellectual production”.  But I will … Continue reading

Posted in AML, Due diligence, General thoughts | Tagged , , , , , , , , | 11 Comments

Pass the popcorn

My telly viewing habits are rather old-fashioned: I like nothing better than watching a repeat of a beloved programme (original “Upstairs, Downstairs” and “Poldark”, I’m talking about you) and I steer clear of anything gory, violent, scary or – saints … Continue reading

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An officer and a target

I’m very familiar with the work of Money Laundering Reporting Officers, Money Laundering Compliance Officers, general compliance officers and police officers.  But I had never heard of Section 151 officers until a money laundering story of relevance to them popped … Continue reading

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Cut on the bias

We’re all biased – there’s no getting away from it.  My own particular unfair bias is against taxi drivers; as a cyclist I have been sworn at, side-swiped and (once) squeezed with my bike against the back of a lorry … Continue reading

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Cleaning house

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest … Continue reading

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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