Tag Archives: legislation

The Brexit bonanza for baddies

You have probably guessed from recent tear-stained posts that I am not a fan of Brexit.  Having lived an international life surrounded – very happily – by people from all over the world, I rear up at the thought of … Continue reading

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Officer politics

One of my main arenas of AML activity is Guernsey, and life there is pretty exciting at the moment with the imminent arrival of new AML legislation and guidance – both already published and coming into force on 31 March … Continue reading

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The award no-one wants

As you know, we are deep in awards season.  (Is anyone else baffled by the all-conquering success of “The Favourite”?  I like Olivia Colman as much as anyone, and the film is certainly entertaining and lovely to look at, but … Continue reading

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Chaos theory?

Regular readers will know that I do a lot of work in Guernsey, and that in general I am a supporter of that jurisdiction’s approach to AML.  However, one issue on which we – Guernsey and I – have long … Continue reading

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The tarnish on golden visas

I have mentioned before the concept of “golden visas” and passports-for-sale.  In today’s politically uncertain world they are becoming ever more popular, and last month Transparency International published a report called “European Getaway: Inside the Murky World of Golden Visas”.  … Continue reading

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Interesting times

I like AML legislation as much as the next person – perhaps more, unless that person is an MLRO.  If there’s updated AML legislation on the horizon I really look forward to it, and I’ve been on tenterhooks for about … Continue reading

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Back to school for AML

British public schools have a lot to answer for – David Cameron, BoJo, Michael Gove, rugby – but to this list we can now add money laundering.  I don’t want to claim any glory (well, maybe just a bit) but … Continue reading

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Once more with conviction

Every few months I indulge myself in a little daydream of doing a PhD in criminology.  Like all good daydreams, it’s rich in lovely feelings – imagine sitting in the library all day, thinking deep thoughts about money laundering, breaking … Continue reading

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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

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