Tag Archives: proceeds of crime

Planes and pandemics

Posted on March 18, 2020 by

One of the challenges of AML work is keeping up with the endless adaptability and imagination of criminals.  Unshackled by moral considerations, or by the need to report to risk committees or by the requirement to comply with legislation (quite … Continue reading →

Posted in Fraud, Money laundering, Organised crime | Tagged , , , , , , , , , , , | 3 Comments

This time it’s personal

Posted on March 11, 2020 by

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading →

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

More Bloody Embezzlement?

Posted on March 4, 2020 by

Just like police officers, customs officers and passport officers, MLROs find themselves doing a certain amount of profiling when it comes to looking for high risk clients.  We know about certain high risk occupations and high risk nationalities and even … Continue reading →

Posted in Bribery and corruption, Money laundering, White collar crime | Tagged , , , , , , , , , | 4 Comments

I beg your pardon

Posted on February 26, 2020 by

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 →

Posted in Bribery and corruption, White collar crime | Tagged , , , , , , , , , , , | 5 Comments

Free for all

Posted on February 19, 2020 by

Just as Voldemort’s name cannot be used for fear of conjuring him up, so too we have declared a taboo in our house on the B word (the one to do with the EU) and on the name of the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering, Organised crime, Supervision, Tax | Tagged , , , , , , , , , , , , | 4 Comments

Regrets, he’s had a few

Posted on February 12, 2020 by

Here in the UK – and I am sure that many countries will have something similar – we have an organisation called the Restorative Justice Council.  The purpose of restorative justice, as explained on the RJC’s website, is “[to bring] … Continue reading →

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

The sniff test

Posted on February 5, 2020 by

The relationship between jewellers and the AML regime is a complicated one.  For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of … Continue reading →

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

Taking money laundering to ‘art

Posted on January 29, 2020 by

“I don’t know much about art, but I know what I like.”  That (very common) attitude might be OK when you’re standing in a gallery trying to make sense of something you’ve seen, but it won’t pass muster if you’re … Continue reading →

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

The special joy of damage joy

Posted on January 15, 2020 by

I remember the first time I was told what schadenfreude means – pleasure derived from another’s misfortune.  I quickly realised what an essential component of life it is, and thought how odd it is that only the Germans have seen … Continue reading →

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

Snatching defeat from the jaws of victory

Posted on December 11, 2019 by

In my opinion, there are countless precious and all but irreplaceable things that the UK will lose if it leaves the EU, including access to many of the EU-wide initiatives, agencies and programmes that make the bloc such a success.  … Continue reading →

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