Tag Archives: FIU

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

Posted in AML, Money laundering, Organised crime, Supervision | Tagged , , , , , , , , , , , , | 8 Comments

Glategny Court jester

“Please God don’t let it be money laundering” and “Heavens above, why can’t they get the concept of source of wealth?” may well be familiar phrases in the lexicon of the MLRO.  But although a greater power – greater even … Continue reading

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The cheque less travelled

One of the things that enticed me to write historical crime novels focusing on financial crime was the realisation – when I was doing some research into the history of a particular bank – that the specific tools may change … Continue reading

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Unsung heroes

My busiest jurisdiction – despite my post a few days ago – is Guernsey.  Working for Guernsey clients takes up about 60% of my time, and thanks to the approachability of their FIU (and in the past – but sadly … 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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The AML rank and file

So here we are, with the final piece of analysis of our AML survey.  The last question was the most complicated: I asked “There are various things that could be done to change the way we approach AML (in principle, … Continue reading

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Jumping on the Brexit bandwagon

Having last week been accused of (or congratulated on – I couldn’t quite tell) being political, I thought I might as well go with the flow.  About three weeks ago I was doing some training in London, talking about the … Continue reading

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Choosing my words carefully

I think I have mentioned to you that a couple of weeks ago I had a call from a researcher at the BBC, asking whether I was a money laundering investigator.  I explained that I wasn’t and off he toddled.  … Continue reading

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SARs in tiaras

I love FIUs, you know I do.  But they do vary enormously in how they interpret (or, perhaps more realistically, can persuade the holders of their government purse strings to interpret) FATF Recommendation 29 that (my emphasis) “Countries should establish … Continue reading

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Once upon a time

Suffering with a cold this week, I rugged up on the sofa with a hot Ribena and the cat and listened to a recording I had made of a Radio 4 production of “The African Queen”, starring Toby Jones and … Continue reading

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