Tag Archives: equivalence

Take my word for it

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading

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A return to the bad old days

You all know how I feel about Brexit, so we shall draw a discreet veil over the months of wailing and gnashing of teeth and rending of garments that have befallen Grossey Mansions.  However, as I had feared, we are … Continue reading

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Game for AML

At some training recently, we had finished the serious business of the day and were cruising into the home straight with a quick round of my Countries Quiz.  As I was asking people to match capital cities to countries, one … Continue reading

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Who’s on the FATF’s naughty step?

So the FATF’s latest take on their list of naughty countries – or, more properly, those jurisdictions with strategic AML/CFT deficiencies – is out.  Their latest plenary meeting, this time in Busan in Korea, ended on 24 June 2016, and … Continue reading

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Jumping on the Brexit bandwagon

Having last week been accused of (or congratulated on – I couldn’t quite tell) being political, I thought I might as well go with the flow.  About three weeks ago I was doing some training in London, talking about the … Continue reading

Posted in AML, Legislation | Tagged , , , , , | 2 Comments

Levels of concern

I like reliable.  I know reliable isn’t exciting, but I’ve always preferred it to unpredictable or ad hoc.  And my byword for reliability is the “International Narcotics Control Strategy Report” which is published by the US Department of State every … Continue reading

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Joining the club

There is always plenty to consider after an FATF plenary meeting, and the most recent one is no exception.  At their end of their meeting in Paris on 19 February, the FATF announced two additions to their membership: Malaysia has … Continue reading

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Beware the EU shortcut

When MLROs are populating their lists of high- and low-risk jurisdictions, they are advised to consult as wide a range of (reputable) sources as possible.  (For non-MLRO readers, the risk status of a jurisdiction matters because if it is judged … Continue reading

Posted in AML, Bribery and corruption | Tagged , , , , , , | 4 Comments

Checking your seatbelt

It would be remiss of me to let “the HSBC situation” go by without comment.  I may well return to it in future, as I know some of the people involved and will try to get some MLRO-relevant details from … Continue reading

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An ugly new word: de-risking

Over the past few years, we in AML have grown used to new terms.  We’ve learnt to leave behind KYC, and concentrate instead on CDD, to replace STRs with SARs.  While taking on board the risk-based approach (another new term), … Continue reading

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