Tag Archives: guidance notes

Hang on every word

I have been called pedantic, but that’s not strictly accurate.  The fact is that I make my living from – and spend much of my leisure time with – words.  Most compliance-y people are good at detail: at school we … Continue reading

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A record number of records

I know I said last time that I wouldn’t be doing anything until the UK’s new Money Laundering Regulations 2017 and their attendant guidance notes are finalised and approved (we’re working towards 26 June 2017), but that doesn’t stop me having … Continue reading

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A state of grace

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

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Sliding into EDD

And here is my third and (for the moment) final post on the UK’s draft new money laundering regulations.  One little phrase jumped out at me in the consultation document: “EDD is a sliding scale”.  The point is made in … Continue reading

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Goldilocks and guidance

As regular readers will know, I am most active in five jurisdictions: UK, Guernsey, Jersey, the Isle of Man and Gibraltar.  I can – and do – work in other places, but I feel most comfortable when I know the … Continue reading

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Overbooked

The Jersey Financial Services Commission recently published a paper entitled “Revisions to Commission AML/CFT Handbooks”, setting out their plans for (big surprise) forthcoming revisions to their handbooks.  As I was working my way through it, putting key dates in my diary … Continue reading

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