Tag Archives: National Crime Agency

Is that wig made of wool or wolf?

A phrase I use quite often in training is, “You’d think so, wouldn’t you?”.  As in, “If the payment is coming to us from another regulated bank, won’t they have done all the checks?”  Or, “Given that CDD checks have … Continue reading

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Money launder-bling

Working in Guernsey this week, I was talking to a client about the concept of the High Value Dealer (under local legislation, those who “[trade] in goods where there is received… a payment or payments in cash of at least … Continue reading

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Operational concerns

It’s the silly season for news (although with Trump and Brexit, it’s hard to tell the difference) so here’s my contribution.  I was paging through the latest annual report from the National Crime Agency, released on 20 July, and I … Continue reading

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Blind faith

The term “professional enabler” has a menacing tone to it, I always think.  We started hearing it back in 2014, when the UK’s National Crime Agency, in its “High End Money Laundering Strategy and Action Plan”, observed this: “The ability … Continue reading

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The UK’s reporting report card

Well, we in the UK are streets ahead of our EU neighbours in one regard at least: the number of SARs we submit to our FIU.  At the start of September, Europol published a report entitled “From Suspicion to Action: … 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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Paying the piper

On 16 November 2016, the UK government’s Home Affairs Select Committee concluded its examination of the UK’s proceeds of crime regime by publishing the government response to the fifth report of the committee in the form of an appendix to … 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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Biting the hand that steals?

Please note that as I fade slightly from view for my summer writing retreat (the fourth Sam Plank novel is nearing completion), for the next month I will blog once a week only, instead of the usual twice.  Back to … Continue reading

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Do something or do nothing

Back in January 2016, the UK government launched an enquiry into “how effectively the measures introduced in the Proceeds of Crime Act 2002, to deprive criminals of any benefit from their crimes, are working [and in particular to] assess the … Continue reading

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