Tag Archives: government

Snatching defeat from the jaws of victory

In my opinion, there are countless precious and all but irreplaceable things that the UK will lose if it leaves the EU, including access to many of the EU-wide initiatives, agencies and programmes that make the bloc such a success.  … Continue reading

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

Vote early, vote often

Thank goodness it’s nearly over: I don’t think I can take much more politicking this year.  Regular readers will know that I loathe, detest and despair at the idea of our leaving the EU and I have voted (postally) accordingly.  … Continue reading

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , , , | 4 Comments

Making AML count

One of the most common requests I hear when designing AML training for clients is for case studies (which I have blogged about recently) and for “lessons learned”.  Alongside this, we have regulators regularly reminding us that their final notices … Continue reading

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

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

Posted in Bribery and corruption, Money laundering | Tagged , , , , , , , , , , | 2 Comments

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

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

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

Posted in AML, Fraud, Money laundering, Organised crime, Publications | Tagged , , , , , , , , , , , , | Leave a comment

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

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

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

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

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

Posted in AML, Money laundering | Tagged , , , , , , , , , , , , , | 4 Comments

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

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