Category Archives: Uncategorized

Muzzle those compliance watchdogs

I went on a Grand Day Out to London last week, and on my way home avoided catching up with emails by reading the (now free) Evening Standard.  My eye was caught, of course, by a story about compliance, because … Continue reading

Posted in AML, Due diligence, Uncategorized | Tagged , , , , , , , | 4 Comments

It’s the taking part that counts

We’ve all been rather obsessed with the Fourth Money Laundering Directive.  Well, we have in my house.  Well, I have – the cat’s not that bothered.  And as a result the UK’s new Serious Crime Act 2015 has slipped into … Continue reading

Posted in Legislation, Organised crime, Uncategorized | Tagged , , , , , , | 6 Comments

Upgrading to a new model

I’ve been hearing from friends in Guernsey that a recent industry presentation there suggested that the familiar three-stage model of money laundering – placement, layering and integration – is out of date.  Granted, it dates from the mid-1980s, but then … Continue reading

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Checking your seatbelt

It would be remiss of me to let “the HSBC situation” go by without comment.  I may well return to it in future, as I know some of the people involved and will try to get some MLRO-relevant details from … Continue reading

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Back Row Boys

Last week I did lots and lots of training sessions in Guernsey, and it gave me an opportunity to consider an issue that I have noticed again and again.  Why, when presented with a room of empty seats, do people … Continue reading

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2014 in review

I wasn’t going to post again until Monday, but the WordPress.com stats helper monkeys have prepared a 2014 annual report for this blog and I thought it might be fun to share it with you. I have also done some … Continue reading

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Due diligence dark glasses

I love words, as you know.  But – like Jaffa Cakes on the shelves and “Today” on Radio 4 in the morning – we sometimes take them for granted.  (Although with the recent sale of United Biscuits to a Turkish … Continue reading

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This blog in 2013 in review

The WordPress.com stats helper monkeys prepared a 2013 annual report for this blog. Here’s an excerpt: The concert hall at the Sydney Opera House holds 2,700 people. This blog was viewed about 13,000 times in 2013. If it were a … Continue reading

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This blog: 2012 in review

As always, the WordPress.com stats helper monkeys have very kindly prepared an annual report for this blog, and you can read all about the most popular posts and the most prolific commenters by clicking on the link below.  Such fun! … Continue reading

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This blog in 2011 – a review

The WordPress.com stats helper monkeys prepared a 2011 annual report for this blog. Here’s an excerpt: A San Francisco cable car holds 60 people. This blog was viewed about 2,600 times in 2011. If it were a cable car, it … Continue reading

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