Tag Archives: financial crime

Feeling the benefit

One of my very favourite things in my professional life is the concept of criminal benefit.  I like what this says about our attitude to crime and those who commit it.  Put very simply – and I am sure a … Continue reading

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Near-o tolerance

A recent article in the Economist made a very valid point about recent AML endeavours – that sometimes they can have unfortunate consequences.  I have blogged quite a bit about “de-risking”, or what the FATF calls “the wholesale cutting loose … Continue reading

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Standing my AML ground

Money laundering and I – or rather, AML and I – have been on intimate terms for more than two decades now.  The muscle memory in my fingers is such that I cannot type the word “money” without following it … Continue reading

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Measuring the uncountable

One of the hardest aspects of any AML regime is measuring its effectiveness.  A bit like insurance, it’s trying to quantify what might have happened if you hadn’t had it.  (That sounds like a nightmare sentence from the translation paper … Continue reading

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Adiós a la Cara de Piña

Panama has been in the news recently for its Papers, but long before then we had Noriega (or “Old Pineapple Face”, as his braver countrymen called him – behind his back, of course).  Indeed, when I started out as a … Continue reading

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A record number of records

I know I said last time that I wouldn’t be doing anything until the UK’s new Money Laundering Regulations 2017 and their attendant guidance notes are finalised and approved (we’re working towards 26 June 2017), but that doesn’t stop me having … Continue reading

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A state of grace

Someone asked me recently about grace.  Not the spiritual kind, or indeed the physical – if there is a loose paving stone within a hundred yards, I will trip over it.  No, what they were concerned about is the period … Continue reading

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More haste, less progress

I’m one of those annoying people who take deadlines really, really seriously.  Last year I accidentally prepared two tax returns because I did the first one so far in advance of the deadline that I clean forgot that I had … Continue reading

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Smile: you’re on ATM camera!

Years ago, I used to joke in AML training sessions that one day CDD would be obsolete because as soon as a baby was born s/he would be tattooed with an indelible barcode which would be used as proof of … Continue reading

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Hold your Criminal Finance horses

Well, it’s here: the Criminal Finances Act 2017 has received Royal Assent.  And it has been quite an education in legislative procedure for me at least.  For instance, did you know that the progress of a Bill (before an Act … Continue reading

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