Tag Archives: PEP

Leak technique

I’ve been doing some remote training recently for a new MLRO, which has been great fun: we’ve covered all the essential and then plenty of those fun, tangential topics that concern MLROs – including beneficial ownership and (our topic for … Continue reading

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Calculators at the ready

Sometimes words enter your vocabulary and you can’t remember where or when you first heard them but suddenly they’re there and you’re hearing and using them all the time.  I’m not talking about “lock-down” or “social distancing” or “flattening the … Continue reading

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No, no, no to UWO, UWO, UWO

Most of us in the world of AML have welcomed the advent of the Unexplained Wealth Order – the court order introduced by the Criminal Finances Act 2017, which can be served to compel either a PEP or someone involved … Continue reading

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I beg your pardon

Baron Black of Crossharbour is not my favourite person, as you may imagine, and it was a dark day in May 2019 when Donald Trump granted him a full pardon, citing Black’s “broad support from many high-profile individuals who have … Continue reading

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The smile on the crocodile

As regular readers will know, last month I spent two weeks in Botswana, on safari.  We saw all the usual amazing beasts (elephants using their trunks as snorkels!), but perhaps the most alarming were the crocodiles – enormous, prehistoric and … Continue reading

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Family values

As I hope is clear from this blog, I work with clients from all over the regulated sector – although I will admit that I have very few law firms (because lawyers like to be trained by other lawyers) and … Continue reading

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Exceeding slow

You remember the summer of ’98.  The European Central Bank was founded in Brussels, Pete Sampras won the men’s singles title at Wimbledon, “Sex and the City” premiered on the telly – and Nigerian dictator Sani Abacha died at the … Continue reading

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Los Pinos of Sherwood Forest

Robin Hood, Robin Hood, riding through the glen – I bet you’re all humming now.  And even though historians have suggested that our Robin was not quite the champion of the poor we choose to believe, the legend persists – … Continue reading

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Something good written by Committee

As you are surely aware, the UK is currently convulsed (almost to the point of turning itself inside out) by a frenzy of self-analysis.  And AML has not escaped the mood of introspection: on 8 March 2019, the House of … Continue reading

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Best foot forward

In recent weeks I have worked in Guernsey and Jersey and I am rather fond of both places – not least because they have rather strict AML regimes, and you know how I feel about taking AML jolly seriously.  Despite … Continue reading

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