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Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.“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
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Recent posts
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
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Blogroll
Tag Archives: PEP
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
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
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 "Kleptopia", AML, CDD, due diligence, kleptocrat, MLRO, money laundering, PEP, proceeds of crime, seizure, source of wealth, Tom Burgis, white collar crime
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 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
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
Posted in AML, Due diligence, Money laundering
Tagged AML, disclosure, due diligence, financial crime, ICIJ, International Consortium of Investigative Journalists, money laundering, Offshore Leaks Database, organised crime, Panama Papers, Paradise Papers, PEP, proceeds of crime, research, risk-based approach, tax evasion, white collar crime
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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
Posted in AML, Bribery and corruption, Money laundering
Tagged AML, bribery, corruption, due diligence, Indonesia, MLRO, money laundering, PEP, regulator, research, risk-based approach
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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
Posted in AML, Bribery and corruption, Money laundering
Tagged AML, Azerbaijan, beneficial ownership, corruption, due diligence, financial crime, government, Kazakhstan, money laundering, National Crime Agency, NCA, PEP, Politically Exposed Person, proceeds of crime, suspicion, tax evasion, Unexplained Wealth Order, UWO
2 Comments
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
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