Tag Archives: FATF

Joining the club

Posted on February 29, 2016 by

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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Plump and rumpled

Posted on February 1, 2016 by

I don’t know how many people rub their hands with glee when the FATF publishes a new report, but I’m one of them.  I find their “typologies” reports, as they used to be called – basically, money laundering and how … Continue reading →

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Confession is good for the soul

Posted on November 12, 2015 by

The lovely film “Out of Africa” contains one of my favourite cinematic lines of all time.  No, it’s not a declaration of love from mahogany Rob to multi-accented Meryl, but rather the response from her dastardly soon-to-be-ex-husband, the splendidly-named Baron … Continue reading →

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High risk movers and shakers

Posted on July 6, 2015 by

The regular updating by the Financial Action Task Force of their list of dodgy places (or, more tactfully, high-risk and non-cooperative jurisdictions) is now part of every MLRO’s diary.  Although I am the first to admit that inclusion on – … Continue reading →

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Glad tidings of bearers

Posted on May 15, 2015 by

Rather lost in all the run-up to the election and the excitement around my holiday, the UK’s Small Business, Enterprise and Employment Act 2015 received Royal Assent on 26 March 2015.  It’s something of a ragbag of an Act, but … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , | 1 Comment

Lifelong learning

Posted on April 27, 2015 by

One of the benefits of the AML/CFT mutual evaluation regime is its reiterative nature – the fact that countries are visited, given a report with suggestions for improvement, and then revisited.  Between visits, governments submit progress reports to keep the … Continue reading →

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Just how close is close?

Posted on December 8, 2014 by

PEPs are a perennial and perplexing problem.  Who they are, how long they stay like that for, and what to do about them anyway – headaches all along the line.  But one aspect of PEPitude that has been exercising (perhaps … Continue reading →

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Nothing to hide

Posted on October 7, 2014 by

As you read this, Guernsey is playing host to an evaluation team from MONEYVAL.  This is one of the first fourth-round evaluations being carried out under the new evaluation methodology, whereby jurisdictions will be rated not only on their AML/CFT … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , | 2 Comments

Time for a PEP talk

Posted on September 25, 2014 by

I have been working in Guernsey this week, and talking (amongst other things) about the proposed changes coming down the line towards us in the Fourth Money Laundering Directive .  (And before anyone says anything, no, Guernsey is not a member … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , | 10 Comments

An ugly new word: de-risking

Posted on August 26, 2014 by

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 →

Posted in AML, Due diligence | Tagged , , , , , , , , , | 3 Comments