Tag Archives: Financial Action Task Force

Grey clouds are gathering

Posted on June 23, 2021 by ihatemoneylaundering

I want to talk about the FATF. First, I think it’s called the “eff-ay-tee-eff” – not “fat-fee” or (occasionally) “faft”. And second, I’m interested in the significance of their grey list (officially, their list of jurisdictions under increased monitoring). Not … Continue reading →

Posted in Uncategorized | Tagged AML, EDD, enhanced due diligence, FATF, Financial Action Task Force, high risk jurisdiction, jurisdiction, MLRO, money laundering, National Risk Assessment, SOF/SOW, source of funds, source of wealth | 5 Comments

Lifelong learning

Posted on June 2, 2021 by ihatemoneylaundering

At the start of my working life, I did a self-assessment questionnaire which indicated that my strengths lay in keeping myself to myself (a team worker I ain’t) and in learning more and more about less and less – in … Continue reading →

Posted in Uncategorized | Tagged AML, anti-money laundering, cryptocurrencies, FATF, Financial Action Task Force, legislation, MLRO, money laundering, Money Laundering Reporting Officer, trade-based money laundering | Leave a comment

Chewing the FATF

Posted on March 3, 2021 by ihatemoneylaundering

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 →

Posted in Uncategorized | Tagged 40 Recommendations, AML, EDD, FATF, Financial Action Task Force, Forty Recommendations, high risk, money laundering, reputational risk | 4 Comments

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

Too much of a bad thing

Posted on April 3, 2019 by ihatemoneylaundering

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 | 7 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 →