Tag Archives: due diligence

Top tips for MLROs

And so here we are: my final weekly blog post.  I could think of no more fitting topic than my top five tips for MLROs, garnered over twenty-five years of working with you. Get people to care.  It’s all very … Continue reading

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Another disappointing report card

You know only too well my views (here and here, for instance) on the ridiculously over-crowded AML supervisory “space” in the UK: we have three statutory supervisors (the Financial Conduct Authority, HMRC and the Gambling Commission) and then 22 “professional … Continue reading

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Underfunded, under-supervised and over here

I know, I know: who thought I would spend my last few months as an AML-er shaking my fist impotently at the madness that is freeports?  But here we are.  I’ve written before (here and here) about why they’re such … Continue reading

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Less than super-vision

I assume most of you know how I feel about the theory of OPBAS – i.e. that the solution to the fragmented and conflicting AML/CFT supervision arrangements in the UK is not to rationalise the number of supervisors but rather … Continue reading

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Frown and gown

I loved being a university student.  I liked pedalling around on my bike, modelling my road positioning, arm signals and indeed wardrobe on those of Miss Jean Brodie (in her prime, gels, as the first two minutes of the movie … Continue reading

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You’d need Speedy Gonzales for all this

The pandemic has put many things on hold – holidays, weddings, house moves – but not the requirement to provide staff with AML/CFT training.  As we head towards September, and people’s minds turn towards a new school term, I am … Continue reading

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Give me a break

I struggle to think of many good things to come out of the pandemic apart from a fabulous recipe for squishy chocolate chip cookies that I unearthed in desperation after the closure of my usual source.  However, it has afforded … Continue reading

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If money laundering were legal…

Well, I’m back, having spent a week in the Suffolk countryside, which encourages a slowing of the pace and a contemplating of the navel.  Just before I went away, a fellow AML enthusiast called Dev Odedra posed this question in … Continue reading

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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

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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

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