Category Archives: Regulation

Glategny Court jester

Posted on August 8, 2018 by

“Please God don’t let it be money laundering” and “Heavens above, why can’t they get the concept of source of wealth?” may well be familiar phrases in the lexicon of the MLRO.  But although a greater power – greater even … Continue reading →

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Training across the Board

Posted on December 18, 2017 by

At the end of each year I do a review of what I have done during that year.  Each time I issue an invoice I categorise it by jurisdiction, by sector and by activity type, and this enables me to … Continue reading →

Posted in AML, Regulation, Training | Tagged , , , , , , , , | 4 Comments

Plea for proof

Posted on October 13, 2017 by

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

Not worth the paper

Posted on September 26, 2012 by

With stories hitting the headlines recently about employees who turn out to be something of a liability (such as Jessica Harper of Lloyds Bank and Kweku Adoboli of UBS), and emphasis being placed by regulators on screening employees, the role … Continue reading →

Posted in Due diligence, Money laundering, Regulation | Tagged , , , | 2 Comments

Innocent until, etc.

Posted on August 10, 2012 by

Last night I went out for dinner with some well-read friends (fish finger sandwich followed by mini doughnuts and chocolate dipping sauce, thank you for asking), and money laundering was the topic du jour.  And I quote: “Your lot are … Continue reading →

Posted in AML, Money laundering, Regulation | Tagged , , , , , , , | 1 Comment

The FSA’s duck shoot

Posted on August 3, 2012 by

When I prepare a new training session, I always try to include a recent case study.  Money laundering stories are easy to find; naughty people are forever committing crimes and then shifting the proceeds around.  On the other hand, anti-money … Continue reading →

Posted in AML, Money laundering, Regulation | Tagged , , , , , , | 5 Comments

I ♥ the FATF (when they prove me right)

Posted on February 29, 2012 by

Unless you have been on retreat in an ashram or stuck in the fog in Guernsey, you will know that the Financial Action Task Force has recently issued a revised version of its 40+9 Recommendations.  For a start, it’s now … Continue reading →

Posted in Legislation, Money laundering, Regulation, Supervision | Tagged , , , , , , | 3 Comments

Deficient or just plain black?

Posted on February 20, 2012 by

I’m a big fan of the Financial Action Task Force – I even call them “eff-ay-tee-eff” as I think this is more respectful than “fat-eff”.  But dealing with them, even at my lowly level of simply reading whatever they publish … Continue reading →

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Girl guidance

Posted on September 28, 2011 by

You know how there are some words you find yourself saying dozens of times a day – diligence, laundering, chocolate.  Well, one I use more than most is “guidance”.  I must have said it a hundred times yesterday, when I … Continue reading →

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The spirit is willing but the risk is too great

Posted on September 23, 2011 by

At a recent training session, when I was explaining the mechanics of Hawala banking, someone asked, “Why don’t we just make it part of the AML regulations?”.  Well.  Quite.  I had gone through the usual stuff about alternative remittance systems … Continue reading →

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