Tag Archives: legislation

An officer and a target

Posted on September 25, 2019 by

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 →

Posted in AML, Due diligence, Legislation, Money laundering | Tagged , , , , , , , , , , | Leave a comment

Words speaking louder than actions

Posted on August 28, 2019 by

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 →

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

The law(yer) is an ass

Posted on August 7, 2019 by

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 →

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

FATF 1, EU 0

Posted on July 17, 2019 by

The Fourth Money Laundering Directive brought us many delights, including Article 9: “Third-country jurisdictions which have strategic deficiencies in their national AML/CFT regimes that pose significant threats to the financial system of the Union (‘high-risk third countries’) shall be identified … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , , | 5 Comments

Facecrook?

Posted on July 10, 2019 by

Here’s what I have read about Facebook Libra: According to the Financial Times, it is “a new global digital currency backed by assets and supported by more than two dozen companies ranging from Visa and Mastercard to Lyft and Spotify”. … Continue reading →

Posted in AML, Money laundering, Regulation, Supervision, Terrorist financing | Tagged , , , , , , , , , , , , | 5 Comments

On their own authority

Posted on July 3, 2019 by

Over a two-decade career in AML, one of the things I have noticed is the “normalisation” of the terms “money laundering” and “AML”.  When I first started out, I had to explain to everyone non-finance-y what money laundering was and … Continue reading →

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Asking for trouble

Posted on May 1, 2019 by

When Brexit is simply too, too depressing, I remind myself that in my own little world at least nothing much is changing.  Cambridge – where I live – is as cosmopolitan and outward-looking as ever, and the Fifth Money Laundering … Continue reading →

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

A dash of pedantry

Posted on April 17, 2019 by

A small matter, this week, but one of great interest to me: to hyphenate or not to hyphenate?  I have always written “money laundering” but there are those – among them, the Economist newspaper, whose style guide I trust in … Continue reading →

Posted in General thoughts, Money laundering | Tagged , , , , , , | 18 Comments

Too much of a bad thing

Posted on April 3, 2019 by

Please may I distract you from the festering plague sore that is Brexit by drawing your attention instead to something we Brits do rather well, which is AML supervision.  In fact we’re so good at this that we have dozens … Continue reading →

Posted in AML, Money laundering, Supervision | Tagged , , , , , , , , , , , , | 7 Comments

Cash and coffee

Posted on March 27, 2019 by

Last week I wrote about the growing (or at least, continuing) popularity of cash in Switzerland, so this week I am looking at the other end of the spectrum.  I recently spent a long weekend in Copenhagen and while I … Continue reading →

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