Category Archives: Publications

Words speaking louder than actions

Now I know it’s important to Think Big – to have goals and targets and ambition.  But you can take it too far.  And I rather think that in their recent “Economic Crime Plan 2019-2022” the joint forces of HMG … Continue reading

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So near and yet so far

At the end of June 2019, the UK’s Gambling Commission – one of our five-star AML regulators, getting top marks from users for both approachability and communication – published its 2018 money laundering and terrorist financing risk assessment.  This examines … Continue reading

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RUSI and the red team

Regular readers will know how I love “crisp” writing: writing that is clear, well-structured, unambiguous and just that little bit elegant.  (Compare and contrast with most of the hurried, rambling and frankly inaccurate drivel that appears online these days.)  Two … Continue reading

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Report from the frontline

It may surprise you to hear that when I was a teenager I wanted to be, no, not a model or an air hostess (as they were called in the dim and distant 1980s) or even an AML specialist, but … Continue reading

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Best foot forward

In recent weeks I have worked in Guernsey and Jersey and I am rather fond of both places – not least because they have rather strict AML regimes, and you know how I feel about taking AML jolly seriously.  Despite … Continue reading

Posted in AML, Bribery and corruption, Money laundering, Publications, Uncategorized | Tagged , , , , , , , , , | 6 Comments

New Guernsey piggies in the sty

A very quick post specifically for my Guernsey readers.  Just for you, I have: Read the new Schedule 3 and Handbook cover to cover Updated all five of my piggy books – for NEDs, and for the accountancy, banking, fiduciary … Continue reading

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Made to measure

About once a year I will say in a dreamy voice, “Perhaps I should do a PhD in criminology…”.  I love the idea of spending months in the library as I craft my thesis, and then becoming the first-ever Dr … Continue reading

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EU, FIUs, STRs and AML

Last week Europol – or, more fully, the European Union Agency for Law Enforcement Cooperation – published a report entitled “From Suspicion to Action – Converting financial intelligence into greater operational impact”.  The report examines the AML framework within the … Continue reading

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I’ll tell you what I want, what I really, really want

Regular readers will know that when it comes to consultations, I am Pavlov’s respondent: tell me you want my opinion and I’m slavering to give it.  Indeed, so regular is my participation that I have a whole email folder entitled … Continue reading

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Thoroughly Modern Piggies

So tell me: what did you do this weekend?  Sit in the garden?  Sail to France?  Slap a few prawns on the barbie?  I did none of these: instead, I sat at my desk, surrounded by the new Money Laundering, … Continue reading

Posted in AML, Legislation, Money laundering, Publications | Tagged , , , , , , , | 10 Comments