Tag Archives: legislation

Latest leak lessons

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

Posted in AML, Money laundering, White collar crime | Tagged , , , , , , , , , , , , , , , , , , | 4 Comments

Sixth sense

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

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

Osh Ghosh begone

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

Posted in Legislation, White collar crime | Tagged , , , , , , , , , , | 5 Comments

Is that why it’s called a PEP rally?

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

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

A word to the wise

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

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

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , , , , | 11 Comments

Levy-hearted

I have my fingers in my ears and am chanting “la la la” to myself, as I refuse to listen to any more corona-chatter.  For today’s blog I am going to pretend that nothing untoward is happening and have a … Continue reading

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

This time it’s personal

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading

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Free for all

Just as Voldemort’s name cannot be used for fear of conjuring him up, so too we have declared a taboo in our house on the B word (the one to do with the EU) and on the name of the … Continue reading

Posted in AML, Bribery and corruption, Money laundering, Organised crime, Supervision, Tax | Tagged , , , , , , , , , , , , | 4 Comments

The sniff test

The relationship between jewellers and the AML regime is a complicated one.  For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of … Continue reading

Posted in AML, Money laundering | Tagged , , , , , , , , , | 9 Comments