Tag Archives: CDD

A mammoth task for the MLRO

Posted on September 22, 2021 by ihatemoneylaundering

A little while ago I was giving a training session and used an analogy that the people attending found useful and amusing.  And, being both vain and generous, I thought I would share it in case it helps with your … Continue reading →

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Could do better

Posted on August 25, 2021 by ihatemoneylaundering

One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading →

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Just do it

Posted on June 16, 2021 by ihatemoneylaundering

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 →

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The wagers of sin

Posted on May 19, 2021 by ihatemoneylaundering

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 →

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The woes of UWOs

Posted on April 21, 2021 by ihatemoneylaundering

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 →

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Systems to manual

Posted on April 14, 2021 by ihatemoneylaundering

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 →

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Back to school

Posted on February 24, 2021 by ihatemoneylaundering

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 →

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I beg your pardon

Posted on February 17, 2021 by ihatemoneylaundering

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 →

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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 →

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Let’s risk it for a Brexit

Posted on December 30, 2020 by ihatemoneylaundering

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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