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

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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

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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

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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

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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

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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

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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

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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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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

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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

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