Tag Archives: guidance

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

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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

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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

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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

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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

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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

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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

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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

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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

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

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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