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Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
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Recent posts
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
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Tag Archives: CDD
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 AML, CDD, certification, KYC, manual, MLRO, money laundering, procedures
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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 AML, bribery, CDD, corruption, money laundering, monitoring, National Crime Agency, NCA, OCCRP, PEP, Russian Laundromat, Transparency International
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 AML, CDD, drug trafficking, due diligence, fit and proper, money laundering, white collar crime
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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 beneficial ownership, CDD, due diligence, Magnitsky Act, MLRO, PEP, Politically Exposed Person, register, sanctions, screening
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
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
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 AML, APG, beneficial ownership, CDD, FATF, MLRO, money laundering, National Risk Assessment, NRA, TBML, trade-based money laundering
4 Comments
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
Posted in Uncategorized
Tagged AML, CDD, compliance, KYC, MLRO, money laundering, Money Laundering Reporting Officer, procedures, record-keeping, training
2 Comments
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
Posted in Uncategorized
Tagged "Kleptopia", AML, CDD, due diligence, kleptocrat, MLRO, money laundering, PEP, proceeds of crime, seizure, source of wealth, Tom Burgis, white collar crime
1 Comment
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
Posted in Uncategorized
Tagged AML, CDD, FCA, GFSC, Guernsey, guidance, identity, KYC, MLRO, money laundering, passport, video ID
16 Comments