Category Archives: Regulation

I ♥ the FATF (when they prove me right)

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

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Deficient or just plain black?

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

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

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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Which law to break? Decisions, decisions…

Although I am not a lawyer, I enjoy the limited exposure I have to the law – it’s like trying to unpick a puzzle, making sure that you have completely understood all the requirements, down to the last sub-clause and … Continue reading

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Sure, you can pat him

You know your neighbour with that enormous dog, the one that snoozes quietly in the garden most of the time, but you’re warned not to turn your back on him “because he’s a bit unpredictable”?  Well, that’s the FSA.  They … Continue reading

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