Tag Archives: legislation

Let’s risk it for a Brexit

Posted on December 30, 2020 by ihatemoneylaundering

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

Posted on November 25, 2020 by ihatemoneylaundering

* 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

Posted on October 28, 2020 by ihatemoneylaundering

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

Posted on October 14, 2020 by ihatemoneylaundering

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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Latest leak lessons

Posted on September 23, 2020 by ihatemoneylaundering

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 →

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Sixth sense

Posted on September 16, 2020 by ihatemoneylaundering

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 →

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Osh Ghosh begone

Posted on September 2, 2020 by ihatemoneylaundering

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 →

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Is that why it’s called a PEP rally?

Posted on August 26, 2020 by ihatemoneylaundering

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 →

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A word to the wise

Posted on July 22, 2020 by ihatemoneylaundering

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 ihatemoneylaundering

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 →

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