Tag Archives: FATF

Is that why it’s called a PEP rally?

Posted on August 26, 2020 by

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

A sprinkling of SAR-dust

Posted on June 17, 2020 by

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime.  Does it shift the burden of investigation from law enforcement to the financial sector?  Does it cost much more than it saves?  Are … Continue reading →

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Making AML count

Posted on November 27, 2019 by

One of the most common requests I hear when designing AML training for clients is for case studies (which I have blogged about recently) and for “lessons learned”.  Alongside this, we have regulators regularly reminding us that their final notices … Continue reading →

Posted in AML, Money laundering, Publications | Tagged , , , , , , , , , , , | 5 Comments

The law(yer) is an ass

Posted on August 7, 2019 by

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 →

Posted in AML, Money laundering | Tagged , , , , , , , , , , , , , | 4 Comments

FATF 1, EU 0

Posted on July 17, 2019 by

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 →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , , | 5 Comments

Facecrook?

Posted on July 10, 2019 by

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 →

Posted in AML, Money laundering, Regulation, Supervision, Terrorist financing | Tagged , , , , , , , , , , , , | 5 Comments

The plain un-SAR-nished truth

Posted on March 6, 2019 by

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS?  “Ruthless trained killers are just a … Continue reading →

Posted in AML, Money laundering, Organised crime, Supervision | Tagged , , , , , , , , , , , , | 8 Comments

Cleaning house

Posted on February 27, 2019 by

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest … Continue reading →

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

Big worries about small accounts

Posted on November 15, 2017 by

The news has been full in recent days of the financial activities of the “super-rich” and fiscally sophisticated.  (That’s my phrase, that last bit, but I can imagine it catching on.  Who knows: we might even start talking about the … Continue reading →

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Curiosity might save the cat

Posted on January 23, 2017 by

One of the management buzz-phrases that seems to be staying the course is “tone from the top”.  In the world of AML, the tone from the top has in fact originated at the bottom: first we had MLROs beating the … Continue reading →

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