Tag Archives: due diligence

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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On their own authority

Over a two-decade career in AML, one of the things I have noticed is the “normalisation” of the terms “money laundering” and “AML”.  When I first started out, I had to explain to everyone non-finance-y what money laundering was and … Continue reading

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Inside the tent but still p***ing in

In my guise as a magistrate I have become familiar with a thrilling document called the “Magistrates’ Court Sentencing Guidelines”.  It’s an entirely public, well, publication, as justice is meant to be transparent and accessible to all.  And if you … Continue reading

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Best foot forward

In recent weeks I have worked in Guernsey and Jersey and I am rather fond of both places – not least because they have rather strict AML regimes, and you know how I feel about taking AML jolly seriously.  Despite … Continue reading

Posted in AML, Bribery and corruption, Money laundering, Publications, Uncategorized | Tagged , , , , , , , , , | 6 Comments

Too much of a bad thing

Please may I distract you from the festering plague sore that is Brexit by drawing your attention instead to something we Brits do rather well, which is AML supervision.  In fact we’re so good at this that we have dozens … Continue reading

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Cash and coffee

Last week I wrote about the growing (or at least, continuing) popularity of cash in Switzerland, so this week I am looking at the other end of the spectrum.  I recently spent a long weekend in Copenhagen and while I … Continue reading

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Cut on the bias

We’re all biased – there’s no getting away from it.  My own particular unfair bias is against taxi drivers; as a cyclist I have been sworn at, side-swiped and (once) squeezed with my bike against the back of a lorry … Continue reading

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