Tag Archives: FATF

The Emirate strikes back

Posted on August 18, 2021 by ihatemoneylaundering

MLROs are used to reacting to lists and warnings issued by governments and by agencies such as the FATF. But when things change rapidly in a jurisdiction, it may be unwise to wait for an official notification, and more sensible … Continue reading →

Posted in Uncategorized | Tagged Afghanistan, APG, Asia/Pacific Group on Money Laudering, EDD, enhanced due diligence, FATF, Financial Action Task Force, high risk jurisdiction, MER, MLRO, mutual evaluation report, Tunisia, Turkey | Leave a comment

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 →