Tag Archives: risk-based approach

Friends in low places

Posted on July 15, 2020 by

For my sins, I start every working day with a trawl of the latest money laundering stories.  As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading →

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

Performance negated pay

Posted on July 8, 2020 by

Much has been written in recent weeks about the pandemic’s impact on AML endeavours – how to conduct CDD checks on clients who cannot leave their homes, and whether to accelerate acceptance of online CDD documents (is the risk of … Continue reading →

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Leak technique

Posted on May 27, 2020 by

I’ve been doing some remote training recently for a new MLRO, which has been great fun: we’ve covered all the essential and then plenty of those fun, tangential topics that concern MLROs – including beneficial ownership and (our topic for … Continue reading →

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

Calculators at the ready

Posted on May 13, 2020 by

Sometimes words enter your vocabulary and you can’t remember where or when you first heard them but suddenly they’re there and you’re hearing and using them all the time.  I’m not talking about “lock-down” or “social distancing” or “flattening the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged , , , , , , , , , , | Leave a comment

The launderer always blinks twice

Posted on April 8, 2020 by

My money laundering news alerts have been very, very quiet in the past fortnight – not for one moment do I think this means that money laundering has stopped, or even decreased markedly, but understandably businesses and law enforcement agencies … Continue reading →

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

Looking to the post-pandemic future

Posted on April 1, 2020 by

I’m not going to attempt to foretell the impact that the current pandemic will have on our financial systems or on financial crime – there are many people much better qualified than I to do that.  For instance, the tip-top … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , , , , | 11 Comments

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 , , , , , , , , , , , | 4 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