Tag Archives: legislation

Is that wig made of wool or wolf?

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

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Made to measure

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

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

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

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Source for the goose

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

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Confession is good for the soul

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

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Turn and face the strange

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  And amongst the usual broken suitcases, comically out-of-date clothes and half … Continue reading

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The world is your lobster, Terence my son

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

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The sands of time

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?

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

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