Tag Archives: guidance

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 , , , , , , , , , , | 1 Comment

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

Posted in AML, Money laundering, Publications, Uncategorized | Tagged , , , , , , , , , | 3 Comments

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

Posted in AML, Due diligence | Tagged , , , , , , | 2 Comments

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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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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Cooking with gas

As I was reminded today when I checked my watch and realised that the numbers seems to have shrunk somewhat, time is passing.  And although we are all now so familiar with the basic principles of the AML regime that … Continue reading

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , | 7 Comments

Now that’s what I call neighbourly

Regular readers will know of my dislike for the UK’s Bribery Act 2010 – or, more specifically, for the corporate offence contained in Section 7 of the Act.  If it were a person, it would be off my Christmas card … Continue reading

Posted in Bribery and corruption, Money laundering | Tagged , , , , , , | Leave a comment

Girl guidance

You know how there are some words you find yourself saying dozens of times a day – diligence, laundering, chocolate.  Well, one I use more than most is “guidance”.  I must have said it a hundred times yesterday, when I … Continue reading

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