Category Archives: Legislation

Cloud cuckoo Brexit

Don’t worry: I’m not going to tell you again how I feel about Brexit.  This update is purely about the AML implications for those of us left behind in the cast-adrift, backwards-looking, isolationist UK.  As you know, the European Fifth … Continue reading

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Going to pot

There is much in the news at the moment about marijuana – legalisation, therapeutic benefits, different strains (Tom Cruise Purple, or Sour Diesel, anyone?).  I have never come within puff of any drug, as I grew up in Singapore where … Continue reading

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Unsung heroes

My busiest jurisdiction – despite my post a few days ago – is Guernsey.  Working for Guernsey clients takes up about 60% of my time, and thanks to the approachability of their FIU (and in the past – but sadly … Continue reading

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The sands of time

I know everyone laughs about jargon – business bingo, anyone? – but I think we’re all guilty of it to some extent.  I know I expect everyone to understand me when I talk about AML, MLROs and the regulated sector, … 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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A return to the bad old days

You all know how I feel about Brexit, so we shall draw a discreet veil over the months of wailing and gnashing of teeth and rending of garments that have befallen Grossey Mansions.  However, as I had feared, we are … Continue reading

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Tax is a feminist issue

I have written before about the interesting differences between the genders when it comes to financial crime.  And now there is a new study, published in the December 2017 issue of the Journal of Behavioural and Experimental Economics (surely you … Continue reading

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Christmas concord and concensus

Experienced MLROs and other professional AML-ers will be familiar with the pattern of EU AML Directives: in essence, you get a new one every decade.  But thanks to the attacks in Paris in November 2015, and the subsequent realisation that … 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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Nipping crime in the (Jersey lily) bud

Following on from my post a few days ago about the LIBOR fines being used as a force for good, I have been interested to read about the allocations made over the past decade in Jersey.  In response to a … Continue reading

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