Tag Archives: government

The smile on the crocodile

As regular readers will know, last month I spent two weeks in Botswana, on safari.  We saw all the usual amazing beasts (elephants using their trunks as snorkels!), but perhaps the most alarming were the crocodiles – enormous, prehistoric and … Continue reading

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An officer and a target

I’m very familiar with the work of Money Laundering Reporting Officers, Money Laundering Compliance Officers, general compliance officers and police officers.  But I had never heard of Section 151 officers until a money laundering story of relevance to them popped … Continue reading

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Words speaking louder than actions

Now I know it’s important to Think Big – to have goals and targets and ambition.  But you can take it too far.  And I rather think that in their recent “Economic Crime Plan 2019-2022” the joint forces of HMG … Continue reading

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So near and yet so far

At the end of June 2019, the UK’s Gambling Commission – one of our five-star AML regulators, getting top marks from users for both approachability and communication – published its 2018 money laundering and terrorist financing risk assessment.  This examines … Continue reading

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RUSI and the red team

Regular readers will know how I love “crisp” writing: writing that is clear, well-structured, unambiguous and just that little bit elegant.  (Compare and contrast with most of the hurried, rambling and frankly inaccurate drivel that appears online these days.)  Two … Continue reading

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The law(yer) is an ass

AML efforts tend to move in one direction: more, greater, stronger, bigger – whatever the right adjective may be.  Occasionally we see an unwinding (as when many jurisdictions removed general insurance business from the AML family) but for the most … Continue reading

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FATF 1, EU 0

The Fourth Money Laundering Directive brought us many delights, including Article 9: “Third-country jurisdictions which have strategic deficiencies in their national AML/CFT regimes that pose significant threats to the financial system of the Union (‘high-risk third countries’) shall be identified … Continue reading

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Facecrook?

Here’s what I have read about Facebook Libra: According to the Financial Times, it is “a new global digital currency backed by assets and supported by more than two dozen companies ranging from Visa and Mastercard to Lyft and Spotify”. … Continue reading

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On their own authority

Over a two-decade career in AML, one of the things I have noticed is the “normalisation” of the terms “money laundering” and “AML”.  When I first started out, I had to explain to everyone non-finance-y what money laundering was and … Continue reading

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Exceeding slow

You remember the summer of ’98.  The European Central Bank was founded in Brussels, Pete Sampras won the men’s singles title at Wimbledon, “Sex and the City” premiered on the telly – and Nigerian dictator Sani Abacha died at the … Continue reading

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