Tag Archives: FIU

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

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , , | Leave a comment

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

Posted in AML, Legislation | Tagged , , , , , | 2 Comments

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

Posted in AML, Money laundering | Tagged , , , , , , , | 2 Comments

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

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 3 Comments

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

Posted in Money laundering, Publications | Tagged , , , , , , | Leave a comment

Quis custodiet ipsos custodes?

Who will guard the guards, asked the Roman poet Juvenal back in the first century, and it is a question that has troubled us ever since.  Last week, Shambhu Prasad Chalise, a section officer at the Department of Money Laundering Investigation (Nepal’s … Continue reading

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , | Leave a comment

Robin red-handed

In a training session earlier this week, we had some lively discussions around the reporting of attempted crime – attempted fraud, attempted money laundering, attempted tax evasion.  Is a SAR suitable or not, we debated, given that SARs (and their … Continue reading

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , , , | 6 Comments

This may be the word of the Lord

The Autorità di Informazione Finanziaria (AIF – the Vatican City’s FIU) has today published its first annual report, covering 2012.  You can see it here – and if you’re not feeling particularly Mediterranean, simply scroll down halfway and it turns … Continue reading

Posted in AML, Money laundering, Supervision | Tagged , , , , , , , , , , | 2 Comments

A Hail Mary pass

(The opportunities for puns in this post are almost endless, so I will try to contain myself.)  On 4 July 2012, MONEYVAL published its first evaluation of the AML/CFT regime of the Holy See.  (I’ve always called it the Vatican, … Continue reading

Posted in AML, Legislation, Supervision | Tagged , , , , , , | 2 Comments

Order, order!

Frustration, irritation, restriction and humiliation.  No, this is not my recipe for marital success, but the welcome result of the application of one or more of an array of Orders that the UK’s Serious Organised Crime Agency now has at … Continue reading

Posted in Legislation, Money laundering, Organised crime | Tagged , , , , , , , , , | 1 Comment