Tag Archives: MLRO

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

Taking money laundering to ‘art

“I don’t know much about art, but I know what I like.”  That (very common) attitude might be OK when you’re standing in a gallery trying to make sense of something you’ve seen, but it won’t pass muster if you’re … Continue reading

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Heading for the exit

One of my great ambitions – which I achieved for a short while in one jurisdiction – is to facilitate communication and foster understanding between the three sides of the AML triangle: regulator, law enforcement and industry.  Now, that’s a … Continue reading

Posted in AML, Money laundering, Regulation | Tagged , , , , , , , , , , , , | 4 Comments

Take my word for it

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading

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Inside the tent but still p***ing in

In my guise as a magistrate I have become familiar with a thrilling document called the “Magistrates’ Court Sentencing Guidelines”.  It’s an entirely public, well, publication, as justice is meant to be transparent and accessible to all.  And if you … 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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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

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