Tag Archives: guidance

Mind your own business

Posted on March 17, 2021 by ihatemoneylaundering

One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators.  Although this can … Continue reading →

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Hang on every word

Posted on March 10, 2021 by ihatemoneylaundering

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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Head, brick wall, etc.

Posted on January 6, 2021 by ihatemoneylaundering

I first started designing and delivering AML training in 1996.  That’s a full quarter-century ago.  And can you imagine how many times I have said, over those twenty-five years, things like “check regularly for PEPs – regulators are hot on … Continue reading →

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Video killed the KYC star

Posted on November 18, 2020 by ihatemoneylaundering

I have been very lucky during my career: thanks to my insatiable quest for information about money laundering and AML, I have learned so much from so many people.  The key, I think, is to listen carefully and to see … Continue reading →

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New Guernsey piggies in the sty

Posted on December 13, 2018 by ihatemoneylaundering

A very quick post specifically for my Guernsey readers.  Just for you, I have: Read the new Schedule 3 and Handbook cover to cover Updated all five of my piggy books – for NEDs, and for the accountancy, banking, fiduciary … Continue reading →

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Keeping up with the Joneses, les Dubois and die Schmidts

Posted on December 7, 2018 by ihatemoneylaundering

I mentioned in my previous post that Guernsey is on the cusp, nay, the very brink of getting new AML legislation.  This represents the conclusion of their exercise to fall into line with the Fourth Money Laundering Directive (or as … Continue reading →

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Interesting times

Posted on November 19, 2018 by ihatemoneylaundering

I like AML legislation as much as the next person – perhaps more, unless that person is an MLRO.  If there’s updated AML legislation on the horizon I really look forward to it, and I’ve been on tenterhooks for about … Continue reading →

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A call to arms

Posted on September 20, 2017 by ihatemoneylaundering

I’ve been in two minds whether or not to do this blog post, as I don’t want to upset anyone, and I can’t think of a particularly clever way to disguise who I am talking about.  Let’s just say that … Continue reading →

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I’ll tell you what I want, what I really, really want

Posted on September 6, 2017 by ihatemoneylaundering

Regular readers will know that when it comes to consultations, I am Pavlov’s respondent: tell me you want my opinion and I’m slavering to give it.  Indeed, so regular is my participation that I have a whole email folder entitled … Continue reading →

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Sliding into EDD

Posted on April 3, 2017 by ihatemoneylaundering

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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