Tag Archives: due diligence

Ho-ho-ho and CDD

I am assuming that one or two of you might be at work today, so let us turn our AML minds to an important seasonal matter: conducting CDD on Father Christmas.  For this particular individual even the most basic identity … Continue reading

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Great-grandpapa’s billions

Like many of you, I have been reading “Kleptopia” by investigative reporter Tom Burgis.  It’s both wonderfully well-written and terrifically depressing.  If there’s a British PM in the past twenty years who hasn’t been advising foreign kleptocrats on how to … Continue reading

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Ethics girls and boys

With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind.  I come from mixed stock: one half of … Continue reading

Posted in AML, Uncategorized, White collar crime | Tagged , , , , , , , , , , | 4 Comments

Latest leak lessons

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”.  I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading

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AML for the autodidact

I’m a big fan of surveys and reports: give me a sniff of a group of compliance types being asked for their take on AML, and I’m there with my hand in the air, begging for the results, like the … Continue reading

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Osh Ghosh begone

I have had no legal training, but on the plus side I have a high boredom threshold and I love reading – both of which are, I believe, essential for lawyers.  This means that I can generally work my way … Continue reading

Posted in Legislation, White collar crime | Tagged , , , , , , , , , , | 5 Comments

Is that why it’s called a PEP rally?

I am of An Age where every working surface in our house has been equipped with a cheap pair of reading glasses – who knows when I will need to read that care label, cooking instruction or baffling piece of … Continue reading

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

Happy holidays!

Well hello everyone – I’m back.  And while I was away on my hols, I did wonder whether taking time off in the summer was the responsible thing to do.  As long ago as 1831, astronomer and statistician Adolphe Quetelet … Continue reading

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A word to the wise

MLROs and compliance folk are creatures of precision.  I (proudly) count myself among them, and I know that when I am designing procedures or assembling training materials or writing this blog, I make sure that I check my sources very … Continue reading

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Friends in low places

For my sins, I start every working day with a trawl of the latest money laundering stories.  As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading

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