Welcome
Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.-
“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
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Recent posts
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
Posting dates
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Blogroll
Tag Archives: guidance
Regrets, I’ve had a few – well, OK, one
As I bring down the curtain on my AML life, I am reflecting in this penultimate post on what I have achieved, the direction my career has taken, and any opportunities missed. To be honest – and this might come … Continue reading
Posted in Uncategorized
Tagged AML, communication, financial crime, guidance, JMLIT, legislation, MLRO, money laundering, RUSI, training
8 Comments
Gone but not un-rotten
Last week a client asked me a question about dead PEPs, and in looking for the answer I realised that this is not a topic addressed by the regulator. Which is odd, given that it is the inevitable final status … Continue reading
Posted in Uncategorized
Tagged AML, bribery, corruption, Guernsey, guidance, legislation, LinkedIn, money laundering, PEP, Politically Exposed Person, risk-based approach
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Mind your own business
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
Posted in Uncategorized
Tagged AML, annual report, Board, directors, FCA, FIU, guidance, JMLSG, MLRO, money laundering, nominated officer, reporting, SAR, suspicion
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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
Posted in Uncategorized
Tagged AML, guidance, guidance notes, legislation, MLRO, Money Laundering Regulations, PEP, source of funds, source of wealth
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Head, brick wall, etc.
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
Posted in Uncategorized
Tagged AML, FCA, Financial Conduct Authority, Guernsey, guidance, money laundering, PEP, Politically Exposed Person, regulator, source of funds
5 Comments
Video killed the KYC star
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
Posted in Uncategorized
Tagged AML, CDD, FCA, GFSC, Guernsey, guidance, identity, KYC, MLRO, money laundering, passport, video ID
16 Comments
New Guernsey piggies in the sty
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
Posted in AML, Money laundering, Publications
Tagged Guernsey, Guernsey Financial Services Commission, guidance, money laundering, publications, training, writing
3 Comments
Keeping up with the Joneses, les Dubois and die Schmidts
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
Posted in AML, Legislation
Tagged AML, directive, guidance, MLD4, MLD5, MLD6, money laundering, Money Laundering Directive, supervisor
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Interesting times
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
Posted in AML, Legislation, Money laundering
Tagged AML, communication, financial crime, government, Guernsey, guidance, legislation, money laundering, publications, training
2 Comments
A call to arms
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
Posted in AML, Legislation, Money laundering
Tagged AML, communication, due diligence, financial crime, government, guidance, legislation, MLRO, money laundering, proceeds of crime, regulation
1 Comment