Tag Archives: legislation

Frown and gown

I loved being a university student.  I liked pedalling around on my bike, modelling my road positioning, arm signals and indeed wardrobe on those of Miss Jean Brodie (in her prime, gels, as the first two minutes of the movie … Continue reading

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You’d need Speedy Gonzales for all this

The pandemic has put many things on hold – holidays, weddings, house moves – but not the requirement to provide staff with AML/CFT training.  As we head towards September, and people’s minds turn towards a new school term, I am … Continue reading

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If money laundering were legal…

Well, I’m back, having spent a week in the Suffolk countryside, which encourages a slowing of the pace and a contemplating of the navel.  Just before I went away, a fellow AML enthusiast called Dev Odedra posed this question in … Continue reading

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Lifelong learning

At the start of my working life, I did a self-assessment questionnaire which indicated that my strengths lay in keeping myself to myself (a team worker I ain’t) and in learning more and more about less and less – in … Continue reading

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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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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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Let’s risk it for a Brexit

Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020.  When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading

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Desperately seeking Regulations

* Alert!  This is a long, ranty post – you may need a Jaffa Cake or two to stay the course…* I’m quite bright.  Not “University Challenge” winning team bright, but I have a couple of degrees, I can sometimes … Continue reading

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Save our SARs

I am a fan of the philosophy of SARs: I think it is correct that businesses handling client money should be obliged to report to the authorities if they suspect that that money is the proceeds of crime or connected … Continue reading

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Free for all

If I were sitting in a mountain-top lair, twirling my moustaches and cackling evilly, I don’t think I could devise an environment more conducive to financial crime than the UK in late 2020.  Put to one side the spinelessness of … Continue reading

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