Tag Archives: FATF

Grey clouds are gathering

Posted on June 23, 2021 by ihatemoneylaundering

I want to talk about the FATF. First, I think it’s called the “eff-ay-tee-eff” – not “fat-fee” or (occasionally) “faft”. And second, I’m interested in the significance of their grey list (officially, their list of jurisdictions under increased monitoring). Not … Continue reading →

Posted in Uncategorized | Tagged AML, EDD, enhanced due diligence, FATF, Financial Action Task Force, high risk jurisdiction, jurisdiction, MLRO, money laundering, National Risk Assessment, SOF/SOW, source of funds, source of wealth | 5 Comments

Lifelong learning

Posted on June 2, 2021 by ihatemoneylaundering

At the start of my working life, I did a self-assessment questionnaire which indicated that my strengths lay in keeping myself to myself (a team worker I ain’t) and in learning more and more about less and less – in … Continue reading →

Posted in Uncategorized | Tagged AML, anti-money laundering, cryptocurrencies, FATF, Financial Action Task Force, legislation, MLRO, money laundering, Money Laundering Reporting Officer, trade-based money laundering | Leave a comment

Chewing the FATF

Posted on March 3, 2021 by ihatemoneylaundering

Last week the FATF met for its regular plenary meeting and – as it does three times a year – updated its list of what I call “dodgy countries”, which are more correctly known as “jurisdictions under increased monitoring”. In … Continue reading →

Posted in Uncategorized | Tagged 40 Recommendations, AML, EDD, FATF, Financial Action Task Force, Forty Recommendations, high risk, money laundering, reputational risk | 4 Comments

Let’s risk it for a Brexit

Posted on December 30, 2020 by ihatemoneylaundering

Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020. When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading →

Posted in Uncategorized | Tagged AML, Brexit, business risk assessment, CDD, FATF, Fourth Money Laundering Directive, legislation, MLRO, money laundering, National Risk Assessment, Recommendations, risk-based approach, sanctions | 4 Comments

Ho-ho-ho and CDD

Posted on December 23, 2020 by ihatemoneylaundering

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 →

Posted in Uncategorized | Tagged CDD, Christmas, client due diligence, corruption, due diligence, enhanced due diligence, FATF, identity, PEP, Politically Exposed Person, source of funds, source of wealth | 6 Comments

Shady trade-y

Posted on December 16, 2020 by ihatemoneylaundering

Right at the start of my working life, just after the Industrial Revolution, I did one of those early personality tests. I’m struggling to remember what it was called (something about umbrellas, or maybe anchors?) but it was meant to … Continue reading →

Posted in Uncategorized | Tagged AML, APG, beneficial ownership, CDD, FATF, MLRO, money laundering, National Risk Assessment, NRA, TBML, trade-based money laundering | 4 Comments

The word from on high

Posted on October 7, 2020 by ihatemoneylaundering

Right, let’s get ready for a quick test of AML TLA [three-letter acronym]: what do the RBA, BRA, RAS and NRA all have in common? Bravo for shouting out “the letter R” – standing, of course, for Risk. As in: … Continue reading →

Posted in Uncategorized | Tagged AML, business risk assessment, FATF, Jersey, money laundering, National Risk Assessment, risk appetite, risk-based approach, terrorist financing | 2 Comments

Is that why it’s called a PEP rally?

Posted on August 26, 2020 by ihatemoneylaundering

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 AML, Bank Secrecy Act, due diligence, FATF, financial crime, government, legislation, money laundering, organised crime, PEP, Politically Exposed Person, proceeds of crime, tax evasion, white collar crime | 4 Comments

A sprinkling of SAR-dust

Posted on June 17, 2020 by ihatemoneylaundering

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 →

Posted in AML, Money laundering | Tagged AML, Bank Secrecy Act, communication, disclosure, due diligence, FATF, financial crime, FinCEN, FIU, fraud, organised crime, proceeds of crime, RUSI, SARs, suspicion, suspicious activity report | Leave a comment

Making AML count

Posted on November 27, 2019 by ihatemoneylaundering

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 →