Category Archives: Regulation

A word to the wise

MLROs and compliance folk are creatures of precision.  I (proudly) count myself among them, and I know that when I am designing procedures or assembling training materials or writing this blog, I make sure that I check my sources very … Continue reading

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Heading for the exit

One of my great ambitions – which I achieved for a short while in one jurisdiction – is to facilitate communication and foster understanding between the three sides of the AML triangle: regulator, law enforcement and industry.  Now, that’s a … Continue reading

Posted in AML, Money laundering, Regulation | Tagged , , , , , , , , , , , , | 4 Comments

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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Facecrook?

Here’s what I have read about Facebook Libra: According to the Financial Times, it is “a new global digital currency backed by assets and supported by more than two dozen companies ranging from Visa and Mastercard to Lyft and Spotify”. … Continue reading

Posted in AML, Money laundering, Regulation, Supervision, Terrorist financing | Tagged , , , , , , , , , , , , | 5 Comments

Glategny Court jester

“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

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

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

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.

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

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The FSA’s duck shoot

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