Tag Archives: AML

A state of grace

Someone asked me recently about grace.  Not the spiritual kind, or indeed the physical – if there is a loose paving stone within a hundred yards, I will trip over it.  No, what they were concerned about is the period … Continue reading

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , | 2 Comments

Smile: you’re on ATM camera!

Years ago, I used to joke in AML training sessions that one day CDD would be obsolete because as soon as a baby was born s/he would be tattooed with an indelible barcode which would be used as proof of … Continue reading

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , | 2 Comments

Hold your Criminal Finance horses

Well, it’s here: the Criminal Finances Act 2017 has received Royal Assent.  And it has been quite an education in legislative procedure for me at least.  For instance, did you know that the progress of a Bill (before an Act … Continue reading

Posted in Bribery and corruption, Legislation, Money laundering | Tagged , , , , , , , | 5 Comments

Conspiring against criminal cash

I have written a few times before about the interesting stage that all countries go through as their criminals (alongside ordinary people, but I’m less interested in them) transition from cash to non-cash working patterns.  As a jurisdiction’s AML regime … Continue reading

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The AML rank and file

So here we are, with the final piece of analysis of our AML survey.  The last question was the most complicated: I asked “There are various things that could be done to change the way we approach AML (in principle, … Continue reading

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Cloudy, with a chance of optimism

I’m not an early adopter, as you probably know: my blog came late to the game (started in 2011, although I hope I have made up for it since then with my doggedness), and my website is rather old-fashioned (I’m … Continue reading

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The law is just the law

For my next survey question, I moved into the realms of fantasy (or at least, I hope it’s fantasy – with Brexit, nothing’s certain any more): “If all the AML obligations were removed from legislation and regulation, what would you … Continue reading

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Power to the AML people

Now that I have whetted your appetites with that first course of participants in my little AML survey, let’s move on to the first meat course: why you do what you do.  The survey question was: “Being totally honest, please … Continue reading

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So that’s who you are!

Well, that was quite an adventure!  My first ever SurveyMonkey survey – and how generous you all were with your time.  I ran my little survey for only two weeks, and in that time 215 – 215! – of you … Continue reading

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Sliding into EDD

And here is my third and (for the moment) final post on the UK’s draft new money laundering regulations.  One little phrase jumped out at me in the consultation document: “EDD is a sliding scale”.  The point is made in … Continue reading

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