Category Archives: Due diligence

The bank of äiti ja isä

I have written before about money laundering staying in the family but it is usually only the adults who are involved.  A recent Finnish case has trodden new ground, with the conviction of a young man – sixteen at the … Continue reading

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Is that wig made of wool or wolf?

A phrase I use quite often in training is, “You’d think so, wouldn’t you?”.  As in, “If the payment is coming to us from another regulated bank, won’t they have done all the checks?”  Or, “Given that CDD checks have … Continue reading

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Source for the goose

I am about to shut down for a fortnight’s holiday – my next blog post will be on Monday 18 June – but I thought I would like to leave you with a clever idea to mull.  No, it’s not … Continue reading

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KISS

Those of us who do AML for a living can sometimes focus on the big stories – the laundering of billions by corrupt PEPs, the emptying of state coffers by oligarchs, the earning of untold wealth by drug barons.  But … Continue reading

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Facing up to laundering

In my last post I sang the praises of a Twitter-bot (I still don’t know what that means) which sends out an alert every time a plane associated with an autocratic regime visits Geneva airport, which strikes me as a … Continue reading

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Pour encourager les autres

In the world of prosecution, it’s sometimes damned if you do and damned if you don’t.  Since the Bribery Act 2010 came into force on 1 July 2011, the UK authorities have had access to the corporate offence of failing … Continue reading

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Even better than Willy Wonka’s Golden Tickets

I’m off on hols to Sri Lanka on Wednesday.  Go on, check out the weather forecast for Galle, and then weep with envy – we’re talking 30˚ and wall-to-wall sunshine.  To secure my week in the sun, I had to … Continue reading

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A rap on the online knuckles

AML regulation of the gambling sector in the UK is complicated; even I (writing as an AML obsessive) am sometimes confused about who is in and who is out.  However, one sector that is most definitely in is online gambling, … Continue reading

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Do unto others

The Guernsey Financial Services Commission has been rather busy recently, what with working away on revised AML/CFT legislation and guidance, and now putting out a pair of publications to explain why and how they regulate the Bailiwick’s financial services sector.  In … Continue reading

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House of horrors?

With the acres of newsprint devoted in recent months to the topic of registration of beneficial ownership, it is interesting to consider the role of the registrars.  Companies – and other structures – are required to submit returns, and to … Continue reading

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