Tag Archives: risk-based approach

Sliding into EDD

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

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ID and me

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!

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

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The slippery slope of blame

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?

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

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Muzzle those compliance watchdogs

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

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

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The plank in your own eye

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

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Low risk is not no risk

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

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An ugly new word: de-risking

Over the past few years, we in AML have grown used to new terms.  We’ve learnt to leave behind KYC, and concentrate instead on CDD, to replace STRs with SARs.  While taking on board the risk-based approach (another new term), … Continue reading

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