Tag Archives: risk-based approach

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 , , , , , , , , | 5 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

Muzzle those compliance watchdogs

Posted on September 28, 2015 by

I went on a Grand Day Out to London last week, and on my way home avoided catching up with emails by reading the (now free) Evening Standard.  My eye was caught, of course, by a story about compliance, because … Continue reading →

Posted in AML, Due diligence, Uncategorized | Tagged , , , , , , , | 4 Comments

The risk of compassion

Posted on September 15, 2015 by

I have just finished reading a book called “A Long Walk Home”, which is an account by Englishwoman Judith Tebbutt of her ordeal of being kidnapped by Somali pirates who killed her husband and then held her at various locations … Continue reading →

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

The plank in your own eye

Posted on April 15, 2015 by

As I was writing my previous blog post, a little thought tweaked at the corner of my mind.  It’s not terribly well-formed (either the thought, or indeed the mind), but here goes.  I was thinking about PEPs and monitoring, and … Continue reading →

Posted in AML, Due diligence | Tagged , , , , , , | 6 Comments

Low risk is not no risk

Posted on September 1, 2014 by

When an institution is devising its risk-based approach to AML, and specifically to customer due diligence procedures, it needs to decide how many categories of risk it will recognise.  The discussions can sometimes take a turn for the philosophical – … Continue reading →

Posted in AML, Due diligence | Tagged , , , , | 3 Comments