Tag Archives: due diligence

Ladies first

In an era when we have the first female Doctor Who, female heads of the Met, the London Fire Brigade and the London Ambulance Service, and a female sort-of-Prime Minister, it is perhaps only right that women should be in … Continue reading

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The law of the wild

In a quest to find a country that is still outward-looking and welcoming, I am going to have a look at Canada this summer.  Although I will still be keeping a weather eye on all things AML, please note that … Continue reading

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Near-o tolerance

A recent article in the Economist made a very valid point about recent AML endeavours – that sometimes they can have unfortunate consequences.  I have blogged quite a bit about “de-risking”, or what the FATF calls “the wholesale cutting loose … Continue reading

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Measuring the uncountable

One of the hardest aspects of any AML regime is measuring its effectiveness.  A bit like insurance, it’s trying to quantify what might have happened if you hadn’t had it.  (That sounds like a nightmare sentence from the translation paper … Continue reading

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Now and forever

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

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A fine fortnight

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

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From little acorns

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

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

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A state of grace

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

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Smile: you’re on ATM camera!

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

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