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Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
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Recent posts
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
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Blogroll
Tag Archives: money laundering
Fishy business
For years, the AML community has been trying to get their message heard at the highest levels of the regulated sector. Business schools have various terms for it, from “tone from the top” to “business culture” to “the rotting fish” … Continue reading
Posted in Uncategorized
Tagged AML, banking, board of directors, CEO, embezzlement, FINMA, money laundering, regulator, senior management, Vatican Bank
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All in the mind
I have a daily Google alert that sends me anything containing the phrase “money laundering”, and earlier this month it sent me down the rabbit-hole of reading about “mental money laundering”. It’s not – as sometimes happens – the simple … Continue reading
Head, brick wall, etc.
I first started designing and delivering AML training in 1996. That’s a full quarter-century ago. And can you imagine how many times I have said, over those twenty-five years, things like “check regularly for PEPs – regulators are hot on … Continue reading
Posted in Uncategorized
Tagged AML, FCA, Financial Conduct Authority, Guernsey, guidance, money laundering, PEP, Politically Exposed Person, regulator, source of funds
5 Comments
Let’s risk it for a Brexit
Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020. When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading
Shady trade-y
Right at the start of my working life, just after the Industrial Revolution, I did one of those early personality tests. I’m struggling to remember what it was called (something about umbrellas, or maybe anchors?) but it was meant to … Continue reading
Posted in Uncategorized
Tagged AML, APG, beneficial ownership, CDD, FATF, MLRO, money laundering, National Risk Assessment, NRA, TBML, trade-based money laundering
4 Comments
It’s just how we’re made
In a normal AML training session I do not have time to deal with the more philosophical aspects of the subject, but when I run extended workshops – as I have been recently – there is scope for delving into … Continue reading
Posted in Uncategorized
Tagged AML, CDD, compliance, KYC, MLRO, money laundering, Money Laundering Reporting Officer, procedures, record-keeping, training
2 Comments
Great-grandpapa’s billions
Like many of you, I have been reading “Kleptopia” by investigative reporter Tom Burgis. It’s both wonderfully well-written and terrifically depressing. If there’s a British PM in the past twenty years who hasn’t been advising foreign kleptocrats on how to … Continue reading
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Tagged "Kleptopia", AML, CDD, due diligence, kleptocrat, MLRO, money laundering, PEP, proceeds of crime, seizure, source of wealth, Tom Burgis, white collar crime
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Desperately seeking Regulations
* Alert! This is a long, ranty post – you may need a Jaffa Cake or two to stay the course…* I’m quite bright. Not “University Challenge” winning team bright, but I have a couple of degrees, I can sometimes … Continue reading
Video killed the KYC star
I have been very lucky during my career: thanks to my insatiable quest for information about money laundering and AML, I have learned so much from so many people. The key, I think, is to listen carefully and to see … Continue reading
Posted in Uncategorized
Tagged AML, CDD, FCA, GFSC, Guernsey, guidance, identity, KYC, MLRO, money laundering, passport, video ID
14 Comments
Outside, looking in
Regular readers will know what a fan I am of Brexit. I think it is the work of the devil, second only to “The One Show” for its ability to take something wonderful and then ruin it for everyone. As … Continue reading
Posted in Uncategorized
Tagged AML, EU, European Commission, European Union, FIU, MLRO, money laundering, NCA, tax evasion, white collar crime
6 Comments