Tag Archives: disclosure

The plain un-SAR-nished truth

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS?  “Ruthless trained killers are just a … Continue reading

Posted in AML, Money laundering, Organised crime, Supervision | Tagged , , , , , , , , , , , , | 8 Comments

Cleaning house

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest … Continue reading

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Officer politics

One of my main arenas of AML activity is Guernsey, and life there is pretty exciting at the moment with the imminent arrival of new AML legislation and guidance – both already published and coming into force on 31 March … Continue reading

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The concept of anonymous publication

We all have a talent, and mine is words.  I love reading and writing them, my spelling is pretty crash-hot, and if I am trying to remember something, I tend to see it as a word, e.g. “I’ve forgotten his … Continue reading

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Nostra culpa

I take no credit at all for spotting this – it’s all down to Timon Molloy, editor and super-sleuth at Money Laundering Bulletin.  But my new favourite financial institution is Danske Bank.  Now I know what you’re thinking: surely they’re … Continue reading

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What’s in a name?

Name changes are a tricky thing.  Remember when Royal Mail decided to call itself Consignia?  That lasted for about a year until it was quietly shelved.  (Mind you, Brad’s Drink was renamed Pepsi-Cola in 1898, and that seems to have … Continue reading

Posted in Due diligence, Legislation, Money laundering | Tagged , , , , , , , , , | 4 Comments

Riches beyond imagination

If you were asked to prove where all of your assets have come from, could you do it?  For myself, I have the mortgage documents for the house, and the original receipt for my car (bought for £4,950 cash in … Continue reading

Posted in AML, Bribery and corruption, Legislation | Tagged , , , , , , , , , , , | 4 Comments

Curiosity might save the cat

One of the management buzz-phrases that seems to be staying the course is “tone from the top”.  In the world of AML, the tone from the top has in fact originated at the bottom: first we had MLROs beating the … Continue reading

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Cash tales from the Raj

I am often asked whether what we are doing in the world of AML – namely due diligence, record-keeping, staff training and reporting of suspicions – is actually having a positive impact.  I’ve mulled on this before, and no doubt … Continue reading

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The forgotten victims

Sometimes, what with all the law and policies and procedures, it is easy to forget that every money laundering or white collar crime case is about people.  Whether they are the perpetrators or the victims, the laundering or other crime … Continue reading

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