“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
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
Tag Archives: PEP
Wolves crying wolf
I’m a bit wary of wading into this topic, as I am something of a dunce when it comes to working out political affiliations and machinations – even after watching a gazillion series of “The West Wing”, I’m still not … Continue reading
Posted in Uncategorized
Tagged AML, conviction, corruption, money laundering, Nicaragua, PEP, Politically Exposed Person, Transparency, Uganda
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Gone but not un-rotten
Last week a client asked me a question about dead PEPs, and in looking for the answer I realised that this is not a topic addressed by the regulator. Which is odd, given that it is the inevitable final status … Continue reading
Posted in Uncategorized
Tagged AML, bribery, corruption, Guernsey, guidance, legislation, LinkedIn, money laundering, PEP, Politically Exposed Person, risk-based approach
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Hang on every word
I have been called pedantic, but that’s not strictly accurate. The fact is that I make my living from – and spend much of my leisure time with – words. Most compliance-y people are good at detail: at school we … Continue reading
Posted in Uncategorized
Tagged AML, guidance, guidance notes, legislation, MLRO, Money Laundering Regulations, PEP, source of funds, source of wealth
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Back to school
When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day … Continue reading
Posted in Uncategorized
Tagged AML, bribery, CDD, corruption, money laundering, monitoring, National Crime Agency, NCA, OCCRP, PEP, Russian Laundromat, Transparency International
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Name and shame
We’re all used to lists and databases. There are sanctions screening systems and PEP screening systems. Within their organisations, MLROs have access to client databases. And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership … Continue reading
Posted in Uncategorized
Tagged beneficial ownership, CDD, due diligence, Magnitsky Act, MLRO, PEP, Politically Exposed Person, register, sanctions, screening
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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
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Ho-ho-ho and CDD
I am assuming that one or two of you might be at work today, so let us turn our AML minds to an important seasonal matter: conducting CDD on Father Christmas. For this particular individual even the most basic identity … Continue reading
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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Latest leak lessons
This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”. I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading
Posted in AML, Money laundering, White collar crime
Tagged AML, communication, corruption, due diligence, Economist, financial crime, government, legislation, MLRO, money laundering, organised crime, Panorama, PEP, proceeds of crime, research, SARs, suspicion, suspicious activity report, white collar crime
4 Comments
Is that why it’s called a PEP rally?
I am of An Age where every working surface in our house has been equipped with a cheap pair of reading glasses – who knows when I will need to read that care label, cooking instruction or baffling piece of … Continue reading
