Tag Archives: proceeds of crime

Dutch courage

One of the dearest ambitions of my little AML-ish heart has been to participate in a think-tank or colloquium or workshop or similar learned gathering, with the aim of influencing AML strategy.  I want to take part not for the … Continue reading

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

The stink of money laundering

Have you ever fibbed slightly about what you do for a living (that you work in AML) in order to avoid yet another tedious story about someone’s grandma who was with her bank for 312 years and STILL had to … Continue reading

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 9 Comments

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

Posted in Bribery and corruption, Money laundering | Tagged , , , , , , , , , , | 2 Comments

An officer and a target

I’m very familiar with the work of Money Laundering Reporting Officers, Money Laundering Compliance Officers, general compliance officers and police officers.  But I had never heard of Section 151 officers until a money laundering story of relevance to them popped … Continue reading

Posted in AML, Due diligence, Legislation, Money laundering | Tagged , , , , , , , , , , | Leave a comment

From little acorns

Apologies for the confusion at the start of my blog post on 4 September: I was not back at all, but actually watching elephants swimming in Botswana.  I wrote a couple of posts in advance, to cover my absence, and … Continue reading

Posted in AML, Fraud, Money laundering | Tagged , , , , , , | Leave a comment

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

Posted in AML, Money laundering | Tagged , , , , , , , , | 8 Comments

Words speaking louder than actions

Now I know it’s important to Think Big – to have goals and targets and ambition.  But you can take it too far.  And I rather think that in their recent “Economic Crime Plan 2019-2022” the joint forces of HMG … Continue reading

Posted in AML, Fraud, Money laundering, Organised crime, Publications | Tagged , , , , , , , , , , , , | Leave a comment

So near and yet so far

At the end of June 2019, the UK’s Gambling Commission – one of our five-star AML regulators, getting top marks from users for both approachability and communication – published its 2018 money laundering and terrorist financing risk assessment.  This examines … Continue reading

Posted in AML, Money laundering, Publications, Regulation | Tagged , , , , , , , , , , | Leave a comment

RUSI and the red team

Regular readers will know how I love “crisp” writing: writing that is clear, well-structured, unambiguous and just that little bit elegant.  (Compare and contrast with most of the hurried, rambling and frankly inaccurate drivel that appears online these days.)  Two … Continue reading

Posted in AML, Money laundering, Publications | Tagged , , , , , , , , , , | Leave a comment

The law(yer) is an ass

AML efforts tend to move in one direction: more, greater, stronger, bigger – whatever the right adjective may be.  Occasionally we see an unwinding (as when many jurisdictions removed general insurance business from the AML family) but for the most … Continue reading

Posted in AML, Money laundering | Tagged , , , , , , , , , , , , , | 4 Comments