Tag Archives: publications

A case in point

I’m ba-ack!  So let’s leap straight in with a complaint.  As every MLRO knows, nothing enlivens an AML training session like a story – known officially as a case study.  At the moment, staff are lapping up details of “the £16 … Continue reading

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

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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

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FATF 1, EU 0

The Fourth Money Laundering Directive brought us many delights, including Article 9: “Third-country jurisdictions which have strategic deficiencies in their national AML/CFT regimes that pose significant threats to the financial system of the Union (‘high-risk third countries’) shall be identified … Continue reading

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On their own authority

Over a two-decade career in AML, one of the things I have noticed is the “normalisation” of the terms “money laundering” and “AML”.  When I first started out, I had to explain to everyone non-finance-y what money laundering was and … Continue reading

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Report from the frontline

It may surprise you to hear that when I was a teenager I wanted to be, no, not a model or an air hostess (as they were called in the dim and distant 1980s) or even an AML specialist, but … Continue reading

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

Cleaning house

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest … Continue reading

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

Adding some blacking to the UK pot

Any crime that generates money can lead to money laundering, but one of the biggies – and one of the most worrying for governments, with its reputational implications – is corruption.  We tend of think of high-level, regime-toppling corruption (naming … Continue reading

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

New Guernsey piggies in the sty

A very quick post specifically for my Guernsey readers.  Just for you, I have: Read the new Schedule 3 and Handbook cover to cover Updated all five of my piggy books – for NEDs, and for the accountancy, banking, fiduciary … Continue reading

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The concept of anonymous publication

We all have a talent, and mine is words.  I love reading and writing them, my spelling is pretty crash-hot, and if I am trying to remember something, I tend to see it as a word, e.g. “I’ve forgotten his … Continue reading

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