Tag Archives: MLD4

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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