Tag Archives: risk-based approach

Planes and pandemics

Posted on March 18, 2020 by

One of the challenges of AML work is keeping up with the endless adaptability and imagination of criminals.  Unshackled by moral considerations, or by the need to report to risk committees or by the requirement to comply with legislation (quite … Continue reading →

Posted in Fraud, Money laundering, Organised crime | Tagged , , , , , , , , , , , | 3 Comments

This time it’s personal

Posted on March 11, 2020 by

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading →

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

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

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

So near and yet so far

Posted on August 21, 2019 by

At the end of June 2019, the UK’s Gambling Commission – one of our five-star AML regulators, getting top marks from users for both approachability and communication – published its 2018 money laundering and terrorist financing risk assessment.  This examines … Continue reading →

Posted in AML, Money laundering, Publications, Regulation | Tagged , , , , , , , , , , | Leave a comment

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