Tag Archives: risk-based approach

The cheque less travelled

Posted on July 25, 2018 by

One of the things that enticed me to write historical crime novels focusing on financial crime was the realisation – when I was doing some research into the history of a particular bank – that the specific tools may change … Continue reading →

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

Do unto others

Posted on December 13, 2017 by

The Guernsey Financial Services Commission has been rather busy recently, what with working away on revised AML/CFT legislation and guidance, and now putting out a pair of publications to explain why and how they regulate the Bailiwick’s financial services sector.  In … Continue reading →

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

Big worries about small accounts

Posted on November 15, 2017 by

The news has been full in recent days of the financial activities of the “super-rich” and fiscally sophisticated.  (That’s my phrase, that last bit, but I can imagine it catching on.  Who knows: we might even start talking about the … Continue reading →

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

Miffed at MiFID II

Posted on October 4, 2017 by

Fifty-two.  That’s how many triple packs of Jaffa Cakes I could have bought with the £138 I have just had to shell out to buy an LEI for my company.  That’s a Legal Entity Identifier: a 20-digit identifying number required … Continue reading →

Posted in Due diligence, Legislation | Tagged , , , , , | Leave a comment

Near-o tolerance

Posted on July 14, 2017 by

A recent article in the Economist made a very valid point about recent AML endeavours – that sometimes they can have unfortunate consequences.  I have blogged quite a bit about “de-risking”, or what the FATF calls “the wholesale cutting loose … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , | 7 Comments

Sliding into EDD

Posted on April 3, 2017 by

And here is my third and (for the moment) final post on the UK’s draft new money laundering regulations.  One little phrase jumped out at me in the consultation document: “EDD is a sliding scale”.  The point is made in … Continue reading →

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

ID and me

Posted on October 10, 2016 by

I’ve just been on holiday to Italy, where – in common with many EU and other countries – it is compulsory to carry photographic ID at all times.  The only photo ID I have is my passport; my driving licence … Continue reading →

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

Ready, steady, MLRO!

Posted on June 24, 2016 by

As regular readers will know, I am rather fond of a biscuit or two – and particularly the Jaffa Cake.  (Yes, it’s a biscuit not a cake, despite the name.  The way to tell is that cakes go hard when … Continue reading →

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

The slippery slope of blame

Posted on June 3, 2016 by

Last weekend we were at a local garden centre – they do lovely cakes – and outside the café they had set up a mock garden.  In it was a children’s slide, with a sign propped up on its steps: … Continue reading →

Posted in AML, Money laundering, Publications | Tagged , , , , , , , | 3 Comments

One size fits all?

Posted on March 24, 2016 by

Recently I was having a chat with a group of “practitioner accountants” – those who run (often quite small) accountancy firms, rather than working as accountants within industry.  We were talking, as you do (well, you do if you’re me) … Continue reading →

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