Tag Archives: MLD4

Keeping up with the Joneses, les Dubois and die Schmidts

I mentioned in my previous post that Guernsey is on the cusp, nay, the very brink of getting new AML legislation.  This represents the conclusion of their exercise to fall into line with the Fourth Money Laundering Directive (or as … Continue reading

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Money laundering is on the cards

A couple of months ago, traffic police in Alabama stopped a car and noticed the smell of marijuana.  They searched the car and found forty gift cards with a total balance of US$19,600, along with “numerous receipts showing repetitive reloading … Continue reading

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A consultation too far?

Regular readers will know that I am quite taken with consultations: I like people asking my opinion nearly as much as I love giving it.  I tend to respond to AML-themed ones most avidly, but in recent months I have … Continue reading

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The luxury of dithering

So here I am, back from my summer writing retreat, and normal blogging has resumed.  It was quite a relief to be out of the country – in Switzerland, to be precise – and get away from all the Brexit … Continue reading

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Wham, bam, no AML, ma’am

Some while ago I wrote about a draft of the Fourth Money Laundering Directive that had sneaked in a much-extended definition of “high value dealers”.  What this earlier draft said was that HVDs would be “other natural or legal persons … Continue reading

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At your service

Last week I was updating several clients on the progress of the Fourth Money Laundering Directive, highlighting for them the changes that I have noticed.  Most proposed changes have received plenty of attention – PEP definition, register of beneficial ownership, … Continue reading

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