Tag Archives: NCA

The plain un-SAR-nished truth

Posted on March 6, 2019 by

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

Posted on February 13, 2019 by

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 , , , , , , , , , , , , | 5 Comments

Is that wig made of wool or wolf?

Posted on September 24, 2018 by

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

Posted on September 19, 2018 by

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 →

Posted in AML, Money laundering | Tagged , , , , , , , , , , | Leave a comment

Operational concerns

Posted on July 30, 2018 by

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 →

Posted in AML, Money laundering | Tagged , , , , , , , , , | 10 Comments

Blind faith

Posted on July 2, 2018 by

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

Posted on November 6, 2017 by

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?

Posted on October 27, 2017 by

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

Posted on November 25, 2016 by

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 →

Posted in AML, Money laundering | Tagged , , , , , , | Leave a comment

Please hold – for six months

Posted on October 28, 2016 by

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