Tag Archives: due diligence

Planes and pandemics

Posted on March 18, 2020 by

One of the challenges of AML work is keeping up with the endless adaptability and imagination of criminals.  Unshackled by moral considerations, or by the need to report to risk committees or by the requirement to comply with legislation (quite … Continue reading →

Posted in Fraud, Money laundering, Organised crime | Tagged , , , , , , , , , , , | 3 Comments

This time it’s personal

Posted on March 11, 2020 by

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading →

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

More Bloody Embezzlement?

Posted on March 4, 2020 by

Just like police officers, customs officers and passport officers, MLROs find themselves doing a certain amount of profiling when it comes to looking for high risk clients.  We know about certain high risk occupations and high risk nationalities and even … Continue reading →

Posted in Bribery and corruption, Money laundering, White collar crime | Tagged , , , , , , , , , | 4 Comments

Free for all

Posted on February 19, 2020 by

Just as Voldemort’s name cannot be used for fear of conjuring him up, so too we have declared a taboo in our house on the B word (the one to do with the EU) and on the name of the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering, Organised crime, Supervision, Tax | Tagged , , , , , , , , , , , , | 4 Comments

Regrets, he’s had a few

Posted on February 12, 2020 by

Here in the UK – and I am sure that many countries will have something similar – we have an organisation called the Restorative Justice Council.  The purpose of restorative justice, as explained on the RJC’s website, is “[to bring] … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , | 4 Comments

The sniff test

Posted on February 5, 2020 by

The relationship between jewellers and the AML regime is a complicated one.  For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of … Continue reading →

Posted in Money laundering, AML | Tagged , , , , , , , , , | 9 Comments

Taking money laundering to ‘art

Posted on January 29, 2020 by

“I don’t know much about art, but I know what I like.”  That (very common) attitude might be OK when you’re standing in a gallery trying to make sense of something you’ve seen, but it won’t pass muster if you’re … Continue reading →

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

The special joy of damage joy

Posted on January 15, 2020 by

I remember the first time I was told what schadenfreude means – pleasure derived from another’s misfortune.  I quickly realised what an essential component of life it is, and thought how odd it is that only the Germans have seen … Continue reading →

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

A piggy new year to everyone

Posted on January 8, 2020 by

Welcome back, one and all.  Well, wasn’t that an exciting festive period?  Just as I was undoing the top button on my skirt, ready to launch into the yard of Jaffa Cakes that my husband (he knows me so well) … Continue reading →

Posted in AML, Legislation, Money laundering, Publications | Tagged , , , , , , , , , | 6 Comments

Take my word for it

Posted on December 18, 2019 by

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading →

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