Tag Archives: beneficial ownership

Registering my displeasure

Posted on May 12, 2021 by ihatemoneylaundering

When I was a schoolgirl, in the late Victorian era, BO had a different meaning: if some poor soul had BO, you flapped your hand in front of your nose and worked the word “deodorant” into your conversation with them … Continue reading →

Posted in Uncategorized | Tagged AML, beneficial ownership, FIU, Guernsey, Guernsey Registry, MLD5, money laundering, PSC register | Leave a comment

Name and shame

Posted on February 10, 2021 by ihatemoneylaundering

We’re all used to lists and databases. There are sanctions screening systems and PEP screening systems. Within their organisations, MLROs have access to client databases. And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership … Continue reading →

Posted in Uncategorized | Tagged beneficial ownership, CDD, due diligence, Magnitsky Act, MLRO, PEP, Politically Exposed Person, register, sanctions, screening | 4 Comments

Shady trade-y

Posted on December 16, 2020 by ihatemoneylaundering

Right at the start of my working life, just after the Industrial Revolution, I did one of those early personality tests. I’m struggling to remember what it was called (something about umbrellas, or maybe anchors?) but it was meant to … Continue reading →

Posted in Uncategorized | Tagged AML, APG, beneficial ownership, CDD, FATF, MLRO, money laundering, National Risk Assessment, NRA, TBML, trade-based money laundering | 4 Comments

No, no, no to UWO, UWO, UWO

Posted on April 29, 2020 by ihatemoneylaundering

Most of us in the world of AML have welcomed the advent of the Unexplained Wealth Order – the court order introduced by the Criminal Finances Act 2017, which can be served to compel either a PEP or someone involved … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, Azerbaijan, beneficial ownership, corruption, due diligence, financial crime, government, Kazakhstan, money laundering, National Crime Agency, NCA, PEP, Politically Exposed Person, proceeds of crime, suspicion, tax evasion, Unexplained Wealth Order, UWO | 2 Comments

The law(yer) is an ass

Posted on August 7, 2019 by ihatemoneylaundering

AML efforts tend to move in one direction: more, greater, stronger, bigger – whatever the right adjective may be. Occasionally we see an unwinding (as when many jurisdictions removed general insurance business from the AML family) but for the most … Continue reading →

Posted in AML, Money laundering | Tagged AML, beneficial ownership, due diligence, FATF, Financial Action Task Force, financial crime, government, lawyer, legislation, money laundering, proceeds of crime, tax evasion, USA, white collar crime | 4 Comments

Launderer seeks splendour without diminishment

Posted on May 15, 2019 by ihatemoneylaundering

It cannot have escaped your notice that Canada is in a lather about its real estate sector being used for money laundering. Stories are appearing seemingly every day about some new scheme or other that has been uncovered, thanks in … Continue reading →

Posted in AML, Money laundering, Organised crime, Uncategorized | Tagged AML, beneficial ownership, Canada, estate agent, FinTRAC, FIU, High Value Dealer, lawyer, luxury vehicles, money laundering, organised crime, real estate | 1 Comment

Cleaning house

Posted on February 27, 2019 by ihatemoneylaundering

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, beneficial ownership, Companies House, disclosure, due diligence, FATF, financial crime, government, legislation, money laundering, publications, research, RUSI | 4 Comments

Voting for AML

Posted on February 5, 2018 by ihatemoneylaundering

I’m not a great fan of many of our current politicians – I’m sure you know why. But I do like Angela Merkel, and in particular Tracy Ullman’s version of Angela Merkel. And I have recently come to admire Elizabeth … Continue reading →

Posted in AML, Money laundering, Uncategorized | Tagged AML, Bank Secrecy Act, beneficial ownership, HSBC, legislation, money laundering | Leave a comment

House of horrors?

Posted on December 4, 2017 by ihatemoneylaundering

With the acres of newsprint devoted in recent months to the topic of registration of beneficial ownership, it is interesting to consider the role of the registrars. Companies – and other structures – are required to submit returns, and to … Continue reading →

Posted in AML, Due diligence, Legislation | Tagged beneficial ownership, Companies House, company, PSC register | 1 Comment

Salvator emptor

Posted on November 24, 2017 by ihatemoneylaundering

The recent record-breaking sale of “Salvator Mundi” highlighted two things – one a surprise, and the other not. The surprise was that this is the most expensive painting by Leonardo DiCaprio that has ever been sold. I kid you not: … Continue reading →