Tag Archives: FATF

Chewing the FATF

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

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Let’s risk it for a Brexit

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

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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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Shady trade-y

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

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The word from on high

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

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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

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A sprinkling of SAR-dust

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

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

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The law(yer) is an ass

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

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FATF 1, EU 0

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

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