Tag Archives: CDD

A mammoth task for the MLRO

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

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

Could do better

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

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

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 , , , , , , , , , , , | 6 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