Tag Archives: reporting

Could do better

One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , , | Leave a comment

Mind your own business

One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators.  Although this can … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , , , | Leave a comment

Save our SARs

I am a fan of the philosophy of SARs: I think it is correct that businesses handling client money should be obliged to report to the authorities if they suspect that that money is the proceeds of crime or connected … Continue reading

Posted in Uncategorized | Tagged , , , , , , , , , , , | 2 Comments

Paying the piper

On 16 November 2016, the UK government’s Home Affairs Select Committee concluded its examination of the UK’s proceeds of crime regime by publishing the government response to the fifth report of the committee in the form of an appendix to … Continue reading

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

Reporting lines – direct or stoppers?

When friends come to visit us in Cambridge, I always warn them to get the fancifully-named Cambridge Cruiser trains – the non-stop ones – rather than the more leisurely stopping service which takes in the delights of Harlow Town, Elsenham … Continue reading

Posted in General thoughts, Legislation | Tagged , , , , , , | 3 Comments