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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
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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
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Blogroll
Tag Archives: FCA
Another disappointing report card
You know only too well my views (here and here, for instance) on the ridiculously over-crowded AML supervisory “space” in the UK: we have three statutory supervisors (the Financial Conduct Authority, HMRC and the Gambling Commission) and then 22 “professional … Continue reading
Less than super-vision
I assume most of you know how I feel about the theory of OPBAS – i.e. that the solution to the fragmented and conflicting AML/CFT supervision arrangements in the UK is not to rationalise the number of supervisors but rather … Continue reading
Could do better
One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading
Posted in Uncategorized
Tagged AML, business risk assessment, CDD, FCA, Financial Conduct Authority, MLRO, PEPs, Regulations, reporting, risk, SARs, suspicion, training
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Loophole in the wall
Cash is a problem during a pandemic. Cash-intensive businesses like nail bars cannot trade, and takeaway food outlets have turned into delivery hubs with payment in advance by card. Luckily, anyone desperate to offload their criminal cash has a new-ish … Continue reading
Posted in Uncategorized
Tagged AML, ATM, banking, Bitcoin, cash, cryptocurrencies, FCA, Financial Conduct Authority, money laundering, money mule
5 Comments
The young and the riskless
I never thought I’d say this, but there are two great advantages to being 55: (a) I’ve had my first covid jab (one shivery night afterwards but apart from that – woohoo!), and (b) I’m not being targeted quite as … Continue reading
Posted in Uncategorized
Tagged FCA, Financial Conduct Authority, fraud, fraudster, investment, MLRO, money laundering, research, risk
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Mind your own business
One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators. Although this can … Continue reading
Posted in Uncategorized
Tagged AML, annual report, Board, directors, FCA, FIU, guidance, JMLSG, MLRO, money laundering, nominated officer, reporting, SAR, suspicion
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Head, brick wall, etc.
I first started designing and delivering AML training in 1996. That’s a full quarter-century ago. And can you imagine how many times I have said, over those twenty-five years, things like “check regularly for PEPs – regulators are hot on … Continue reading
Posted in Uncategorized
Tagged AML, FCA, Financial Conduct Authority, Guernsey, guidance, money laundering, PEP, Politically Exposed Person, regulator, source of funds
5 Comments
Video killed the KYC star
I have been very lucky during my career: thanks to my insatiable quest for information about money laundering and AML, I have learned so much from so many people. The key, I think, is to listen carefully and to see … Continue reading
Posted in Uncategorized
Tagged AML, CDD, FCA, GFSC, Guernsey, guidance, identity, KYC, MLRO, money laundering, passport, video ID
16 Comments
Too much of a bad thing
Please may I distract you from the festering plague sore that is Brexit by drawing your attention instead to something we Brits do rather well, which is AML supervision. In fact we’re so good at this that we have dozens … Continue reading
Posted in AML, Money laundering, Supervision
Tagged AML, due diligence, FCA, Financial Action Task Force, financial crime, Gambling Commission, government, HMRC, legislation, money laundering, OPBAS, RUSI, supervision
9 Comments
The concept of anonymous publication
We all have a talent, and mine is words. I love reading and writing them, my spelling is pretty crash-hot, and if I am trying to remember something, I tend to see it as a word, e.g. “I’ve forgotten his … Continue reading