Tag Archives: MLRO

The AML rank and file

So here we are, with the final piece of analysis of our AML survey.  The last question was the most complicated: I asked “There are various things that could be done to change the way we approach AML (in principle, … Continue reading

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Cloudy, with a chance of optimism

I’m not an early adopter, as you probably know: my blog came late to the game (started in 2011, although I hope I have made up for it since then with my doggedness), and my website is rather old-fashioned (I’m … Continue reading

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The law is just the law

For my next survey question, I moved into the realms of fantasy (or at least, I hope it’s fantasy – with Brexit, nothing’s certain any more): “If all the AML obligations were removed from legislation and regulation, what would you … Continue reading

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Power to the AML people

Now that I have whetted your appetites with that first course of participants in my little AML survey, let’s move on to the first meat course: why you do what you do.  The survey question was: “Being totally honest, please … Continue reading

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Queen of all I survey

I’ve been doing this AML malarkey now for a quarter of a century.  It was never the grand plan, but it seems that I have devoted my working life to keeping criminal money out of the financial and related systems.  … Continue reading

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Please hold – for six months

The Criminal Finances Bill is out, described in the Home Office press release as “legislation to tackle money laundering and corruption, recover the proceeds of crime and counter terrorist financing”.  When it was at the consultation stage, I responded – … 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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Ready, steady, MLRO!

As regular readers will know, I am rather fond of a biscuit or two – and particularly the Jaffa Cake.  (Yes, it’s a biscuit not a cake, despite the name.  The way to tell is that cakes go hard when … Continue reading

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An MLRO of one’s own

At a training session recently, someone asked me about the reporting regime in their firm, and whether they had to send their SAR via their manager.  Oh no, I said – in fact, definitely don’t send it via the manager, … Continue reading

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Order, order – Unexplained Wealth Order

There’s nothing new under the sun, they say, and Unexplained Wealth Orders certainly comply with that dictum.  On 21 April 2016 the UK government announced its action plan (these days a simple plan is not enough: it must be galvanised … Continue reading

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