Tag Archives: guidance

Gone but not un-rotten

Posted on April 28, 2021 by ihatemoneylaundering

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 | Leave a comment

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 →

Posted in Uncategorized | Tagged AML, annual report, Board, directors, FCA, FIU, guidance, JMLSG, MLRO, money laundering, nominated officer, reporting, SAR, suspicion | Leave a comment

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 →

Posted in Uncategorized | Tagged AML, guidance, guidance notes, legislation, MLRO, Money Laundering Regulations, PEP, source of funds, source of wealth | Leave a comment

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 →

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

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 →

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

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 →

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

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 →

Posted in AML, Legislation | Tagged AML, directive, guidance, MLD4, MLD5, MLD6, money laundering, Money Laundering Directive, supervisor | Leave a comment

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 →

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

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 →

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

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 →