Tag Archives: proceeds of crime

Latest leak lessons

Posted on September 23, 2020 by

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

Sixth sense

Posted on September 16, 2020 by

Right, here’s a little quiz for you: as of today, it’s 78 days until what?  Points deducted if you simply say, “Thursday 3 December” – although points added if you know that that’s my mother-in-law’s birthday [note to self: remind … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , | 6 Comments

Osh Ghosh begone

Posted on September 2, 2020 by

I have had no legal training, but on the plus side I have a high boredom threshold and I love reading – both of which are, I believe, essential for lawyers.  This means that I can generally work my way … Continue reading →

Posted in Legislation, White collar crime | Tagged , , , , , , , , , , | 5 Comments

Is that why it’s called a PEP rally?

Posted on August 26, 2020 by

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

Friends in low places

Posted on July 15, 2020 by

For my sins, I start every working day with a trawl of the latest money laundering stories.  As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 2 Comments

Performance negated pay

Posted on July 8, 2020 by

Much has been written in recent weeks about the pandemic’s impact on AML endeavours – how to conduct CDD checks on clients who cannot leave their homes, and whether to accelerate acceptance of online CDD documents (is the risk of … Continue reading →

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Data doom and delight

Posted on June 24, 2020 by

With writing a post once a week only (I’ve fallen into writing longer posts less frequently – hope that’s OK), there’s sometimes a bit of a delay until I get round to dealing with something that’s been in the news.  … Continue reading →

Posted in AML, Money laundering, Training | Tagged , , , , , , , , , , , , , | 5 Comments

A sprinkling of SAR-dust

Posted on June 17, 2020 by

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime.  Does it shift the burden of investigation from law enforcement to the financial sector?  Does it cost much more than it saves?  Are … Continue reading →

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A most tempting offer

Posted on June 10, 2020 by

The name of my company is the result of a family joke: my father observed one day that I was always thinking about crime.  I wasn’t sure I’d be allowed to have the name but I was, and it’s memorable … Continue reading →

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

Leak technique

Posted on May 27, 2020 by

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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