Category Archives: Due diligence

Maman’s the word

I know that AML and CFT go together.  I’m not convinced that they belong together, but I am swimming against the tide, which seems to favour putting all financial crime into the same category.  And so I am careful to … Continue reading

Posted in Due diligence, Terrorist financing | Tagged , , , , | 5 Comments

Plea for proof

Over two decades of AML training, I have heard many questions over and over again.  I don’t mind this at all, and I like to think that I have refined my answers so that they are more succinct and helpful.  … Continue reading

Posted in AML, Due diligence, Regulation | Tagged , , , , | 2 Comments

Miffed at MiFID II

Fifty-two.  That’s how many triple packs of Jaffa Cakes I could have bought with the £138 I have just had to shell out to buy an LEI for my company.  That’s a Legal Entity Identifier: a 20-digit identifying number required … Continue reading

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Regime change for the better

The UK Financial Conduct Authority’s Senior Managers and Certification Regime is now two years old.  Under the regime (which currently applies to UK banks, building societies, credit unions, branches of foreign banks operating in the UK and the largest investment … Continue reading

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The law of the wild

In a quest to find a country that is still outward-looking and welcoming, I am going to have a look at Canada this summer.  Although I will still be keeping a weather eye on all things AML, please note that … 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

Posted in AML, Due diligence, Legislation | Tagged , , , , , , , , | 9 Comments

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

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

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

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

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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