Tag Archives: research

Take my word for it

Posted on December 18, 2019 by

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , , , , , , | 1 Comment

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

Making AML count

Posted on November 27, 2019 by

One of the most common requests I hear when designing AML training for clients is for case studies (which I have blogged about recently) and for “lessons learned”.  Alongside this, we have regulators regularly reminding us that their final notices … Continue reading →

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

Copyright or copy wrong?

Posted on November 6, 2019 by

As an author, I am rather keen on the concept of copyright – the noun first being used in, we are told, 1729 to mean “the exclusive right to make and sell copies of an intellectual production”.  But I will … Continue reading →

Posted in AML, Due diligence, General thoughts | Tagged , , , , , , , , | 11 Comments

A case in point

Posted on September 4, 2019 by

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 , , , , , , , , | 10 Comments

Facecrook?

Posted on July 10, 2019 by

Here’s what I have read about Facebook Libra: According to the Financial Times, it is “a new global digital currency backed by assets and supported by more than two dozen companies ranging from Visa and Mastercard to Lyft and Spotify”. … Continue reading →

Posted in AML, Money laundering, Regulation, Supervision, Terrorist financing | Tagged , , , , , , , , , , , , | 5 Comments

Report from the frontline

Posted on June 19, 2019 by

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

Something good written by Committee

Posted on April 24, 2019 by

As you are surely aware, the UK is currently convulsed (almost to the point of turning itself inside out) by a frenzy of self-analysis.  And AML has not escaped the mood of introspection: on 8 March 2019, the House of … Continue reading →

Posted in AML, Money laundering, Supervision | Tagged , , , , , , | 1 Comment

Cut on the bias

Posted on March 13, 2019 by

We’re all biased – there’s no getting away from it.  My own particular unfair bias is against taxi drivers; as a cyclist I have been sworn at, side-swiped and (once) squeezed with my bike against the back of a lorry … Continue reading →

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

Cleaning house

Posted on February 27, 2019 by

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