Tag Archives: MLRO

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

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

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , | 1 Comment

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

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , | 2 Comments

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

Posted in AML, Money laundering | Tagged , , , , , , , , | 5 Comments

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

A reliability rating for Regs

I regularly visit Switzerland which, being such a lumpy little country, has a lot of weather – and many ways in which the weather can kill you (avalanches, mountain mists, tsunamis, etc.).  (I know you won’t believe me about the … Continue reading

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It’s for you-hoo!

Apart from the days when I am out preaching the AML gospel, I work alone in an office above my garage.  Although this means that I get all the Jaffa Cakes and can break off to dance to ABBA’s “When … Continue reading

Posted in AML, Training | Tagged , , , | 12 Comments

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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