Tag Archives: legislation

The special joy of damage joy

I remember the first time I was told what schadenfreude means – pleasure derived from another’s misfortune.  I quickly realised what an essential component of life it is, and thought how odd it is that only the Germans have seen … Continue reading

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A piggy new year to everyone

Welcome back, one and all.  Well, wasn’t that an exciting festive period?  Just as I was undoing the top button on my skirt, ready to launch into the yard of Jaffa Cakes that my husband (he knows me so well) … Continue reading

Posted in AML, Legislation, Money laundering, Publications | Tagged , , , , , , , , , | 4 Comments

Take my word for it

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading

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Snatching defeat from the jaws of victory

In my opinion, there are countless precious and all but irreplaceable things that the UK will lose if it leaves the EU, including access to many of the EU-wide initiatives, agencies and programmes that make the bloc such a success.  … Continue reading

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Vote early, vote often

Thank goodness it’s nearly over: I don’t think I can take much more politicking this year.  Regular readers will know that I loathe, detest and despair at the idea of our leaving the EU and I have voted (postally) accordingly.  … Continue reading

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Making AML count

One of the most common requests I hear when designing AML training for clients is for case studies (which I have blogged about recently) and for “lessons learned”.  Alongside this, we have regulators regularly reminding us that their final notices … Continue reading

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Copyright or copy wrong?

As an author, I am rather keen on the concept of copyright – the noun first being used in, we are told, 1729 to mean “the exclusive right to make and sell copies of an intellectual production”.  But I will … Continue reading

Posted in AML, Due diligence, General thoughts | Tagged , , , , , , , , | 11 Comments

An officer and a target

I’m very familiar with the work of Money Laundering Reporting Officers, Money Laundering Compliance Officers, general compliance officers and police officers.  But I had never heard of Section 151 officers until a money laundering story of relevance to them popped … Continue reading

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Words speaking louder than actions

Now I know it’s important to Think Big – to have goals and targets and ambition.  But you can take it too far.  And I rather think that in their recent “Economic Crime Plan 2019-2022” the joint forces of HMG … Continue reading

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The law(yer) is an ass

AML efforts tend to move in one direction: more, greater, stronger, bigger – whatever the right adjective may be.  Occasionally we see an unwinding (as when many jurisdictions removed general insurance business from the AML family) but for the most … Continue reading

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