Tag Archives: legislation

Is that wig made of wool or wolf?

Posted on September 24, 2018 by

A phrase I use quite often in training is, “You’d think so, wouldn’t you?”.  As in, “If the payment is coming to us from another regulated bank, won’t they have done all the checks?”  Or, “Given that CDD checks have … Continue reading →

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

Made to measure

Posted on August 17, 2018 by

About once a year I will say in a dreamy voice, “Perhaps I should do a PhD in criminology…”.  I love the idea of spending months in the library as I craft my thesis, and then becoming the first-ever Dr … Continue reading →

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

It’s coming home – if we pay its fare

Posted on July 11, 2018 by

No doubt you are all – well, my English and Croatian readers at least – dusting off your scarves and vocal cords for tonight’s match.  (Personally, I am speaking at a literary event in a local village – we’re not … Continue reading →

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

Minnows and whales

Posted on July 6, 2018 by

At the end of June 2018, the Attorney General of British Columbia held a press conference to launch a report into his province’s gambling industry and its possible facilitation of money laundering.  Any uncertainty on the matter was removed pretty … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , , | Leave a comment

Source for the goose

Posted on June 1, 2018 by

I am about to shut down for a fortnight’s holiday – my next blog post will be on Monday 18 June – but I thought I would like to leave you with a clever idea to mull.  No, it’s not … Continue reading →

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

Confession is good for the soul

Posted on May 9, 2018 by

Today’s question: in what way is an AML trainer like a Catholic priest?  Let me set the scene (which I shall keep deliberately vague, for reasons that shall become obvious).  Some time ago I was invited in to see a … Continue reading →

Posted in AML, Money laundering, Training | Tagged , , , , , , , , | Leave a comment

Turn and face the strange

Posted on May 4, 2018 by

I am in reflective mood.  Over a recent wet weekend my husband and I tidied out our loft.  (I know: not for us a glamorous mini-break in San Tropez.)  And amongst the usual broken suitcases, comically out-of-date clothes and half … Continue reading →

Posted in AML, Training | Tagged , , , , , , , , , , , | 10 Comments

The world is your lobster, Terence my son

Posted on April 30, 2018 by

One of the main challenges I face in AML training – which I have been doing since Abraham was a lad, it seems – is making people care about it.  I am quite immune to the groans and slumps that … Continue reading →

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

The sands of time

Posted on April 16, 2018 by

I know everyone laughs about jargon – business bingo, anyone? – but I think we’re all guilty of it to some extent.  I know I expect everyone to understand me when I talk about AML, MLROs and the regulated sector, … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , | 8 Comments

Stick, or big, fat, juicy carrot?

Posted on April 11, 2018 by

I’ve been thinking quite a bit recently about personal accountability for AML failings, and whether or not it is a good idea.  This has been prompted in part by the FCA’s extension of its Senior Managers and Certification Regime, and … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , | Leave a comment