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 , , , , , , , , | Leave a comment

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 , , , , , , , , , , | Leave a comment

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 , , , , , , , , | Leave a comment

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 , , , , , , , , , , , | 6 Comments

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 , , , , , , , , , | 4 Comments

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

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

Posted in Uncategorized | Tagged , , , , , , , , , , , | 6 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

Posted in Uncategorized | Tagged , , , , , , , , , , , , | 1 Comment

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 , , , , , , , , , , , , , , , , , , | 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

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