Category Archives: Due diligence

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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Salvator emptor

The recent record-breaking sale of “Salvator Mundi” highlighted two things – one a surprise, and the other not.  The surprise was that this is the most expensive painting by Leonardo DiCaprio that has ever been sold.  I kid you not: … Continue reading

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Big worries about small accounts

The news has been full in recent days of the financial activities of the “super-rich” and fiscally sophisticated.  (That’s my phrase, that last bit, but I can imagine it catching on.  Who knows: we might even start talking about the … Continue reading

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What’s in a name?

Name changes are a tricky thing.  Remember when Royal Mail decided to call itself Consignia?  That lasted for about a year until it was quietly shelved.  (Mind you, Brad’s Drink was renamed Pepsi-Cola in 1898, and that seems to have … Continue reading

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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 , , , , | 8 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 , , , , | 4 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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