Welcome
Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
-
Recent posts
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
Posting dates
June 2022 M T W T F S S 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Categories
Tags
- AML
- asset forfeiture
- banking
- beneficial ownership
- Bitcoin
- bribery
- Bribery Act 2010
- cash
- casino
- CDD
- communication
- compliance
- conferences
- corruption
- disclosure
- due diligence
- equivalence
- estate agent
- FATF
- FCA
- Financial Action Task Force
- Financial Conduct Authority
- financial crime
- FIU
- fraud
- FSA
- Gambling Commission
- government
- Guernsey
- Guernsey Financial Services Commission
- guidance
- High Value Dealer
- HMRC
- HM Treasury
- Isle of Man
- Jersey
- legislation
- mafia
- MLD4
- ML Regulations
- MLRO
- money laundering
- Money Laundering Bulletin
- Money Laundering Regulations
- Money Laundering Reporting Officer
- National Crime Agency
- National Risk Assessment
- NCA
- non-executive directors
- organised crime
- PEP
- Politically Exposed Person
- proceeds of crime
- Proceeds of Crime Act
- publications
- regulation
- regulator
- research
- risk
- risk-based approach
- SARs
- Serious Organised Crime Agency
- slavery
- SOCA
- source of funds
- source of wealth
- Susan Grossey
- suspicion
- tax evasion
- terrorist financing
- Thinking about Crime Limited
- training
- Transparency International
- white collar crime
- writing
Blogroll
Tag Archives: FATF
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
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
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 AML, communication, FATF, Financial Action Task Force, financial crime, government, legislation, organised crime, proceeds of crime, publications, research, RUSI
5 Comments
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
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
Facecrook?
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
The plain un-SAR-nished truth
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
Cleaning house
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 AML, beneficial ownership, Companies House, disclosure, due diligence, FATF, financial crime, government, legislation, money laundering, publications, research, RUSI
4 Comments
Big worries about small accounts
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
Curiosity might save the cat
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
Who’s on the FATF’s naughty step?
So the FATF’s latest take on their list of naughty countries – or, more properly, those jurisdictions with strategic AML/CFT deficiencies – is out. Their latest plenary meeting, this time in Busan in Korea, ended on 24 June 2016, and … Continue reading