Tag Archives: MLRO

Cloud cuckoo Brexit

Don’t worry: I’m not going to tell you again how I feel about Brexit.  This update is purely about the AML implications for those of us left behind in the cast-adrift, backwards-looking, isolationist UK.  As you know, the European Fifth … Continue reading

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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

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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What’s in a name?

Name changes are a tricky thing.  Remember when Royal Mail decided to call itself Consignia?  That lasted for about a year until it was quietly shelved.  (Mind you, Brad’s Drink was renamed Pepsi-Cola in 1898, and that seems to have … Continue reading

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Maman’s the word

I know that AML and CFT go together.  I’m not convinced that they belong together, but I am swimming against the tide, which seems to favour putting all financial crime into the same category.  And so I am careful to … Continue reading

Posted in Due diligence, Terrorist financing | Tagged , , , , | 8 Comments

Regime change for the better

The UK Financial Conduct Authority’s Senior Managers and Certification Regime is now two years old.  Under the regime (which currently applies to UK banks, building societies, credit unions, branches of foreign banks operating in the UK and the largest investment … Continue reading

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A call to arms

I’ve been in two minds whether or not to do this blog post, as I don’t want to upset anyone, and I can’t think of a particularly clever way to disguise who I am talking about.  Let’s just say that … Continue reading

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Standing my AML ground

Money laundering and I – or rather, AML and I – have been on intimate terms for more than two decades now.  The muscle memory in my fingers is such that I cannot type the word “money” without following it … Continue reading

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Measuring the uncountable

One of the hardest aspects of any AML regime is measuring its effectiveness.  A bit like insurance, it’s trying to quantify what might have happened if you hadn’t had it.  (That sounds like a nightmare sentence from the translation paper … Continue reading

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Yippee – more acronyms!

Last week I discovered that something that exercised me a great deal – the “once a PEP, always a PEP” stance of Guernsey, Jersey and the Isle of Man – did not seem to concern the MLROs in those jurisdictions … Continue reading

Posted in AML, Legislation, Money laundering | Tagged , , , , , | 16 Comments