Tag Archives: National Crime Agency

The plain un-SAR-nished truth

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS?  “Ruthless trained killers are just a … Continue reading

Posted in AML, Money laundering, Organised crime, Supervision | Tagged , , , , , , , , , , , , | 8 Comments

The Brexit bonanza for baddies

You have probably guessed from recent tear-stained posts that I am not a fan of Brexit.  Having lived an international life surrounded – very happily – by people from all over the world, I rear up at the thought of … Continue reading

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , , | 7 Comments

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

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

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

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

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

Posted in AML, Legislation | Tagged , , , , , , , , | 3 Comments

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

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

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