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Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
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Recent posts
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
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Blogroll
Tag Archives: risk-based approach
Let’s risk it for a Brexit
Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020. When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading
The word from on high
Right, let’s get ready for a quick test of AML TLA [three-letter acronym]: what do the RBA, BRA, RAS and NRA all have in common? Bravo for shouting out “the letter R” – standing, of course, for Risk. As in: … Continue reading
Ethics girls and boys
With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind. I come from mixed stock: one half of … Continue reading
Posted in AML, Uncategorized, White collar crime
Tagged AML, communication, due diligence, ethics, financial crime, fraud, money laundering, research, risk-based approach, suspicion, training
4 Comments
Happy holidays!
Well hello everyone – I’m back. And while I was away on my hols, I did wonder whether taking time off in the summer was the responsible thing to do. As long ago as 1831, astronomer and statistician Adolphe Quetelet … Continue reading
Friends in low places
For my sins, I start every working day with a trawl of the latest money laundering stories. As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading
Performance negated pay
Much has been written in recent weeks about the pandemic’s impact on AML endeavours – how to conduct CDD checks on clients who cannot leave their homes, and whether to accelerate acceptance of online CDD documents (is the risk of … Continue reading
Posted in AML, Due diligence, Money laundering
Tagged AML, bonus, due diligence, financial crime, MLRO, money laundering, proceeds of crime, remuneration, risk-based approach, training
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Leak technique
I’ve been doing some remote training recently for a new MLRO, which has been great fun: we’ve covered all the essential and then plenty of those fun, tangential topics that concern MLROs – including beneficial ownership and (our topic for … Continue reading
Posted in AML, Due diligence, Money laundering
Tagged AML, disclosure, due diligence, financial crime, ICIJ, International Consortium of Investigative Journalists, money laundering, Offshore Leaks Database, organised crime, Panama Papers, Paradise Papers, PEP, proceeds of crime, research, risk-based approach, tax evasion, white collar crime
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Calculators at the ready
Sometimes words enter your vocabulary and you can’t remember where or when you first heard them but suddenly they’re there and you’re hearing and using them all the time. I’m not talking about “lock-down” or “social distancing” or “flattening the … Continue reading
Posted in AML, Bribery and corruption, Money laundering
Tagged AML, bribery, corruption, due diligence, Indonesia, MLRO, money laundering, PEP, regulator, research, risk-based approach
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The launderer always blinks twice
My money laundering news alerts have been very, very quiet in the past fortnight – not for one moment do I think this means that money laundering has stopped, or even decreased markedly, but understandably businesses and law enforcement agencies … Continue reading
Posted in AML, Due diligence, Money laundering
Tagged AML, communication, due diligence, financial crime, government, Guernsey, money laundering, proceeds of crime, research, risk-based approach
7 Comments
Looking to the post-pandemic future
I’m not going to attempt to foretell the impact that the current pandemic will have on our financial systems or on financial crime – there are many people much better qualified than I to do that. For instance, the tip-top … Continue reading