Tag Archives: CDD

Just do it

Sportswear and I rarely coincide, but I am a fan of the slogan “Just do it”.  Years ago a much-respected older friend gave me his top tip for efficiency: if you think of a job that needs doing and it … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , , | 2 Comments

The wagers of sin

What do Ben Affleck and Jennifer Tilly have in common?  If you said that they were once in a relationship, that’s the wrong Jennifer – Ben was married to Jennifer Garner and engaged to Jennifer Lopez (creating the social media … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , | 5 Comments

The woes of UWOs

Unexplained Wealth Orders are now three years old.  Although many would like to see their reach expanded – divorce lawyers are particularly interested – they remain available only in cases involving PEPs or those suspected of serious criminality.  And indeed, … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , , , | Leave a comment

Systems to manual

I have a confession: I love writing AML manuals.  I know, I know – it’s akin to saying that for Sunday lunch I enjoy a nice roast kitten with puppy gravy, but there it is.  Who knows when it started, … Continue reading

Posted in Uncategorized | Tagged , , , , , , , | 2 Comments

Back to school

When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , | 5 Comments

I beg your pardon

In the last few days of the presidency of Donald Trump, when he was granting pardons to his chums and executing three black men and a woman while his mob was looting the Capitol, I read a tweet that has … Continue reading

Posted in Uncategorized | Tagged , , , , , , | Leave a comment

Name and shame

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 , , , , , , , , , | 4 Comments

Let’s risk it for a Brexit

Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020.  When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , , | 4 Comments

Ho-ho-ho and CDD

I am assuming that one or two of you might be at work today, so let us turn our AML minds to an important seasonal matter: conducting CDD on Father Christmas.  For this particular individual even the most basic identity … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , | 6 Comments

Shady trade-y

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 , , , , , , , , , , | 4 Comments