Tag Archives: due diligence

Dutch courage

One of the dearest ambitions of my little AML-ish heart has been to participate in a think-tank or colloquium or workshop or similar learned gathering, with the aim of influencing AML strategy.  I want to take part not for the … Continue reading

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The stink of money laundering

Have you ever fibbed slightly about what you do for a living (that you work in AML) in order to avoid yet another tedious story about someone’s grandma who was with her bank for 312 years and STILL had to … Continue reading

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An officer and a target

I’m very familiar with the work of Money Laundering Reporting Officers, Money Laundering Compliance Officers, general compliance officers and police officers.  But I had never heard of Section 151 officers until a money laundering story of relevance to them popped … Continue reading

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From little acorns

Apologies for the confusion at the start of my blog post on 4 September: I was not back at all, but actually watching elephants swimming in Botswana.  I wrote a couple of posts in advance, to cover my absence, and … Continue reading

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Family values

As I hope is clear from this blog, I work with clients from all over the regulated sector – although I will admit that I have very few law firms (because lawyers like to be trained by other lawyers) and … Continue reading

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Words speaking louder than actions

Now I know it’s important to Think Big – to have goals and targets and ambition.  But you can take it too far.  And I rather think that in their recent “Economic Crime Plan 2019-2022” the joint forces of HMG … Continue reading

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So near and yet so far

At the end of June 2019, the UK’s Gambling Commission – one of our five-star AML regulators, getting top marks from users for both approachability and communication – published its 2018 money laundering and terrorist financing risk assessment.  This examines … Continue reading

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The law(yer) is an ass

AML efforts tend to move in one direction: more, greater, stronger, bigger – whatever the right adjective may be.  Occasionally we see an unwinding (as when many jurisdictions removed general insurance business from the AML family) but for the most … Continue reading

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FATF 1, EU 0

The Fourth Money Laundering Directive brought us many delights, including Article 9: “Third-country jurisdictions which have strategic deficiencies in their national AML/CFT regimes that pose significant threats to the financial system of the Union (‘high-risk third countries’) shall be identified … Continue reading

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Facecrook?

Here’s what I have read about Facebook Libra: According to the Financial Times, it is “a new global digital currency backed by assets and supported by more than two dozen companies ranging from Visa and Mastercard to Lyft and Spotify”. … Continue reading

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