Tag Archives: FIU

A sprinkling of SAR-dust

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

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Looking to the post-pandemic future

I’m not going to attempt to foretell the impact that the current pandemic will have on our financial systems or on financial crime – there are many people much better qualified than I to do that.  For instance, the tip-top … Continue reading

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Launderer seeks splendour without diminishment

It cannot have escaped your notice that Canada is in a lather about its real estate sector being used for money laundering.  Stories are appearing seemingly every day about some new scheme or other that has been uncovered, thanks in … Continue reading

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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

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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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