Tag Archives: CDD

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

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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

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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

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It’s just how we’re made

In a normal AML training session I do not have time to deal with the more philosophical aspects of the subject, but when I run extended workshops – as I have been recently – there is scope for delving into … Continue reading

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Great-grandpapa’s billions

Like many of you, I have been reading “Kleptopia” by investigative reporter Tom Burgis.  It’s both wonderfully well-written and terrifically depressing.  If there’s a British PM in the past twenty years who hasn’t been advising foreign kleptocrats on how to … Continue reading

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Video killed the KYC star

I have been very lucky during my career: thanks to my insatiable quest for information about money laundering and AML, I have learned so much from so many people.  The key, I think, is to listen carefully and to see … Continue reading

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A word to the wise

MLROs and compliance folk are creatures of precision.  I (proudly) count myself among them, and I know that when I am designing procedures or assembling training materials or writing this blog, I make sure that I check my sources very … Continue reading

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Best foot forward

In recent weeks I have worked in Guernsey and Jersey and I am rather fond of both places – not least because they have rather strict AML regimes, and you know how I feel about taking AML jolly seriously.  Despite … Continue reading

Posted in AML, Bribery and corruption, Money laundering, Publications, Uncategorized | Tagged , , , , , , , , , | 6 Comments

Cut on the bias

We’re all biased – there’s no getting away from it.  My own particular unfair bias is against taxi drivers; as a cyclist I have been sworn at, side-swiped and (once) squeezed with my bike against the back of a lorry … Continue reading

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Something in the way she moves

A while ago I wrote about facial recognition software being used for client identification at ATMs and to apprehend scallywags out in public.  But of course technology does not stand still, and one of the shortcomings of facial recognition software … Continue reading

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