Tag Archives: procedures

Systems to manual

I have a confession: I love writing AML manuals.  I know, I know – it’s akin to saying that for Sunday lunch I enjoy a nice roast kitten with puppy gravy, but there it is.  Who knows when it started, … Continue reading

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It’s just how we’re made

In a normal AML training session I do not have time to deal with the more philosophical aspects of the subject, but when I run extended workshops – as I have been recently – there is scope for delving into … Continue reading

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Pour encourager les autres

In the world of prosecution, it’s sometimes damned if you do and damned if you don’t.  Since the Bribery Act 2010 came into force on 1 July 2011, the UK authorities have had access to the corporate offence of failing … Continue reading

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Moving the goalposts

I’m as fond of AML measures as the next person.  Actually, that’s a fib: I’m probably a thousand times fonder of AML measures than the next person.  But more than two decades of AML endeavours have taught me one important … Continue reading

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Knowing when to know

After a recent training visit to Gibraltar, I was sitting in the departure lounge at the airport.  A woman sat down next to me and – seeing me not reading and assuming that I wanted to chat (actually, I was … Continue reading

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