Tag Archives: due diligence

Now and forever

Posted on June 12, 2017 by

As regular readers will know, I have a great fondness for Guernsey.  It has a mild climate, lovely scenery, excellent food – and a rather admirable AML regime.  (That last bit doesn’t make it into the VisitGuernsey brochures or telly … Continue reading →

Posted in AML, Due diligence, Legislation | Tagged , , , , , , , , | 9 Comments

A fine fortnight

Posted on June 7, 2017 by

What else could I blog about today but the seemingly daily fines on financial institutions for AML failings?  Here’s what has happened (you can see the links to all of these stories on the Newsroom page of my website): 22 … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , | 1 Comment

From little acorns

Posted on June 2, 2017 by

I work regularly in the UK and four UK-related jurisdictions, and for those five I take pains to learn their AML legislation, regulation and guidance.  When it comes to the other jurisdictions of the world and their AML regimes, I … Continue reading →

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A record number of records

Posted on May 24, 2017 by

I know I said last time that I wouldn’t be doing anything until the UK’s new Money Laundering Regulations 2017 and their attendant guidance notes are finalised and approved (we’re working towards 26 June 2017), but that doesn’t stop me having … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , | 5 Comments

A state of grace

Posted on May 19, 2017 by

Someone asked me recently about grace.  Not the spiritual kind, or indeed the physical – if there is a loose paving stone within a hundred yards, I will trip over it.  No, what they were concerned about is the period … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , | 2 Comments

Smile: you’re on ATM camera!

Posted on May 10, 2017 by

Years ago, I used to joke in AML training sessions that one day CDD would be obsolete because as soon as a baby was born s/he would be tattooed with an indelible barcode which would be used as proof of … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , | 2 Comments

The AML rank and file

Posted on April 26, 2017 by

So here we are, with the final piece of analysis of our AML survey.  The last question was the most complicated: I asked “There are various things that could be done to change the way we approach AML (in principle, … Continue reading →

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Cloudy, with a chance of optimism

Posted on April 21, 2017 by

I’m not an early adopter, as you probably know: my blog came late to the game (started in 2011, although I hope I have made up for it since then with my doggedness), and my website is rather old-fashioned (I’m … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , , | 2 Comments

The law is just the law

Posted on April 18, 2017 by

For my next survey question, I moved into the realms of fantasy (or at least, I hope it’s fantasy – with Brexit, nothing’s certain any more): “If all the AML obligations were removed from legislation and regulation, what would you … Continue reading →

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Power to the AML people

Posted on April 12, 2017 by

Now that I have whetted your appetites with that first course of participants in my little AML survey, let’s move on to the first meat course: why you do what you do.  The survey question was: “Being totally honest, please … Continue reading →

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