Tag Archives: risk-based approach

Asking for trouble

Posted on May 1, 2019 by

When Brexit is simply too, too depressing, I remind myself that in my own little world at least nothing much is changing.  Cambridge – where I live – is as cosmopolitan and outward-looking as ever, and the Fifth Money Laundering … Continue reading →

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

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

Just do the math

Posted on December 17, 2018 by

I am currently reading “How Not to Be Wrong” by American mathematician Jordan Ellenberg.  Not that I am wrong very often, of course, but it pays to protect one’s elevated position.  In truth, I scraped by in my maths A-level, … Continue reading →

Posted in Due diligence, Fraud, Money laundering, Organised crime | Tagged , , , , , , , , | 2 Comments

Chaos theory?

Posted on December 3, 2018 by

Regular readers will know that I do a lot of work in Guernsey, and that in general I am a supporter of that jurisdiction’s approach to AML.  However, one issue on which we – Guernsey and I – have long … Continue reading →

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

The tarnish on golden visas

Posted on November 28, 2018 by

I have mentioned before the concept of “golden visas” and passports-for-sale.  In today’s politically uncertain world they are becoming ever more popular, and last month Transparency International published a report called “European Getaway: Inside the Murky World of Golden Visas”.  … Continue reading →

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

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 →

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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 →

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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