Category Archives: Legislation

PEP promises

My short AML survey is still live (until 31 March 2017) so please do have a go if you haven’t yet: https://www.surveymonkey.co.uk/r/VM62T6K A few days ago I mentioned that I have responded to a consultation on draft new money laundering regulations … Continue reading

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The magical disappearing regulations

My short AML survey is still live (until 31 March 2017) so please do have a go if you haven’t yet: https://www.surveymonkey.co.uk/r/VM62T6K Oooo, you know how a love a good consultation, and this week I’ve been enjoying one close to home: … Continue reading

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Don’t do as I do

It will not surprise you to learn that I am no fan of Donald Trump; I think he is ill-informed, unprepared, tactless, uncontrolled and just plain nasty – and that’s on a good day.  But there’s not much I can … Continue reading

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When legislation lets you down

For a couple of years I have been tracking the fortunes of “Les W”.  The Wildensteins are one of the highest-profile families in France; Wildenstein & Co was one of the most successful and influential art dealerships of the last … Continue reading

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Moving the goalposts

I’m as fond of AML measures as the next person.  Actually, that’s a fib: I’m probably a thousand times fonder of AML measures than the next person.  But more than two decades of AML endeavours have taught me one important … Continue reading

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Please hold – for six months

The Criminal Finances Bill is out, described in the Home Office press release as “legislation to tackle money laundering and corruption, recover the proceeds of crime and counter terrorist financing”.  When it was at the consultation stage, I responded – … Continue reading

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All about prepositions

On 11 September 2016 (following industry consultation that said that current CDD requirements are too burdensome), the Australian Anti-Money Laundering and Counter-Terrorism Financing Rules Amendment Instrument 2016 (No. 1) came into force, amending Chapter 4 of the Anti-Money Laundering and … Continue reading

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A welcome mat for money launderers

For some months, a Home Affairs Select Committee of the UK parliament, under the chairmanship of Keith Vaz MP, has been taking evidence about the effectiveness of the UK’s proceeds of crime regime.  It has not been a happy story, … Continue reading

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The luxury of dithering

So here I am, back from my summer writing retreat, and normal blogging has resumed.  It was quite a relief to be out of the country – in Switzerland, to be precise – and get away from all the Brexit … Continue reading

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Brexit and AML

The UK has voted to leave the EU.  I am devastated, of course, but that is a personal sadness.  From a professional point of view, my concern is what will happen to the AML legislation that we in the UK … Continue reading

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