Tag Archives: legislation

Latest leak lessons

Posted on September 23, 2020 by

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”.  I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading →

Posted in AML, Money laundering, White collar crime | Tagged , , , , , , , , , , , , , , , , , , | 4 Comments

Sixth sense

Posted on September 16, 2020 by

Right, here’s a little quiz for you: as of today, it’s 78 days until what?  Points deducted if you simply say, “Thursday 3 December” – although points added if you know that that’s my mother-in-law’s birthday [note to self: remind … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , | 6 Comments

Osh Ghosh begone

Posted on September 2, 2020 by

I have had no legal training, but on the plus side I have a high boredom threshold and I love reading – both of which are, I believe, essential for lawyers.  This means that I can generally work my way … Continue reading →

Posted in Legislation, White collar crime | Tagged , , , , , , , , , , | 5 Comments

Is that why it’s called a PEP rally?

Posted on August 26, 2020 by

I am of An Age where every working surface in our house has been equipped with a cheap pair of reading glasses – who knows when I will need to read that care label, cooking instruction or baffling piece of … Continue reading →

Posted in AML, Due diligence, Legislation, Money laundering | Tagged , , , , , , , , , , , , , | 4 Comments

A word to the wise

Posted on July 22, 2020 by

MLROs and compliance folk are creatures of precision.  I (proudly) count myself among them, and I know that when I am designing procedures or assembling training materials or writing this blog, I make sure that I check my sources very … Continue reading →

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Looking to the post-pandemic future

Posted on April 1, 2020 by

I’m not going to attempt to foretell the impact that the current pandemic will have on our financial systems or on financial crime – there are many people much better qualified than I to do that.  For instance, the tip-top … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , , , , | 11 Comments

Levy-hearted

Posted on March 25, 2020 by

I have my fingers in my ears and am chanting “la la la” to myself, as I refuse to listen to any more corona-chatter.  For today’s blog I am going to pretend that nothing untoward is happening and have a … Continue reading →

Posted in AML, Legislation, Money laundering, Supervision | Tagged , , , , , , , , | 2 Comments

This time it’s personal

Posted on March 11, 2020 by

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading →

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

Free for all

Posted on February 19, 2020 by

Just as Voldemort’s name cannot be used for fear of conjuring him up, so too we have declared a taboo in our house on the B word (the one to do with the EU) and on the name of the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering, Organised crime, Supervision, Tax | Tagged , , , , , , , , , , , , | 4 Comments

The sniff test

Posted on February 5, 2020 by

The relationship between jewellers and the AML regime is a complicated one.  For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , , | 9 Comments