Tag Archives: FATF

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 →

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

Posted on August 7, 2019 by ihatemoneylaundering

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 →

Posted in AML, Money laundering | Tagged AML, beneficial ownership, due diligence, FATF, Financial Action Task Force, financial crime, government, lawyer, legislation, money laundering, proceeds of crime, tax evasion, USA, white collar crime | 4 Comments

FATF 1, EU 0

Posted on July 17, 2019 by ihatemoneylaundering

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 →

Posted in AML, Legislation, Money laundering | Tagged AML, communication, due diligence, European Commission, European Union, FATF, Financial Action Task Force, government, legislation, MLD4, MLD5, money laundering, publications | 5 Comments

Facecrook?

Posted on July 10, 2019 by ihatemoneylaundering

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 →

Posted in AML, Money laundering, Regulation, Supervision, Terrorist financing | Tagged AML, cryptocurrencies, due diligence, Facebook, FATF, Financial Action Task Force, financial crime, government, legislation, Libra, money laundering, proceeds of crime, research | 5 Comments

The plain un-SAR-nished truth

Posted on March 6, 2019 by ihatemoneylaundering

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 →

Posted in AML, Money laundering, Organised crime, Supervision | Tagged AML, disclosure, due diligence, FATF, Financial Conduct Authority, financial crime, FIU, government, National Crime Agency, National Risk Assessment, NCA, SARs, Solicitors Regulation Authority | 8 Comments

Cleaning house

Posted on February 27, 2019 by ihatemoneylaundering

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

Posted on November 15, 2017 by ihatemoneylaundering

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 →

Posted in AML, Due diligence, Money laundering | Tagged AML, due diligence, FATF, Financial Action Task Force, financial inclusion, government, legislation, money laundering, risk-based approach | Leave a comment

Curiosity might save the cat

Posted on January 23, 2017 by ihatemoneylaundering

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 →

Posted in AML, Money laundering | Tagged AML, casino, communication, disclosure, due diligence, FATF, Financial Action Task Force, financial crime, Gambling Commission, legislation, money laundering, proceeds of crime | Leave a comment

Who’s on the FATF’s naughty step?

Posted on July 1, 2016 by ihatemoneylaundering

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 →