Tag Archives: government

A state of grace

Posted on May 19, 2017 by

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 →

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

More haste, less progress

Posted on May 15, 2017 by

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!

Posted on May 10, 2017 by

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 →

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

Hold your Criminal Finance horses

Posted on May 5, 2017 by

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 →

Posted in Bribery and corruption, Legislation, Money laundering | Tagged , , , , , , , | 5 Comments

Conspiring against criminal cash

Posted on May 2, 2017 by

I have written a few times before about the interesting stage that all countries go through as their criminals (alongside ordinary people, but I’m less interested in them) transition from cash to non-cash working patterns.  As a jurisdiction’s AML regime … Continue reading →

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The AML rank and file

Posted on April 26, 2017 by

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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PEP promises

Posted on March 29, 2017 by

My short AML survey is still live (until 31 March 2017) so please do have a go if you haven’t yet: https://www.surveymonkey.co.uk/r/VM62T6K A few days ago I mentioned that I have responded to a consultation on draft new money laundering regulations … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , | 6 Comments

The magical disappearing regulations

Posted on March 24, 2017 by

My short AML survey is still live (until 31 March 2017) so please do have a go if you haven’t yet: https://www.surveymonkey.co.uk/r/VM62T6K Oooo, you know how a love a good consultation, and this week I’ve been enjoying one close to home: … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , | 5 Comments

Wishing you a speedy recovery

Posted on March 10, 2017 by

I have been working in Jersey this week, and at the start of the week it was announced that Jersey has undertaken to return to Kenya over £3 million of stolen assets, in an agreement signed by the Jersey Chief … Continue reading →

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Don’t do as I do

Posted on February 15, 2017 by

It will not surprise you to learn that I am no fan of Donald Trump; I think he is ill-informed, unprepared, tactless, uncontrolled and just plain nasty – and that’s on a good day.  But there’s not much I can … Continue reading →

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