“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
Tag Archives: risk-based approach
Less than super-vision
I assume most of you know how I feel about the theory of OPBAS – i.e. that the solution to the fragmented and conflicting AML/CFT supervision arrangements in the UK is not to rationalise the number of supervisors but rather … Continue reading
A new chapter for financial crime
When you live in a country with a Prime Minister who is alleged to have said in April 2021 that he would rather see “bodies pile high in their thousands” than order a third lockdown, and who now confirms that “we … Continue reading
Posted in Uncategorized
Tagged abuse, AML, Chancellor, corruption, financial crime, fraud, HM Treasury, HMG, MLRO, money laundering, regulation, risk-based approach
Leave a comment
Gone but not un-rotten
Last week a client asked me a question about dead PEPs, and in looking for the answer I realised that this is not a topic addressed by the regulator. Which is odd, given that it is the inevitable final status … Continue reading
Posted in Uncategorized
Tagged AML, bribery, corruption, Guernsey, guidance, legislation, LinkedIn, money laundering, PEP, Politically Exposed Person, risk-based approach
Leave a comment
Let’s risk it for a Brexit
Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020. When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading
The word from on high
Right, let’s get ready for a quick test of AML TLA [three-letter acronym]: what do the RBA, BRA, RAS and NRA all have in common? Bravo for shouting out “the letter R” – standing, of course, for Risk. As in: … Continue reading
Ethics girls and boys
With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind. I come from mixed stock: one half of … Continue reading
Posted in AML, Uncategorized, White collar crime
Tagged AML, communication, due diligence, ethics, financial crime, fraud, money laundering, research, risk-based approach, suspicion, training
4 Comments
Happy holidays!
Well hello everyone – I’m back. And while I was away on my hols, I did wonder whether taking time off in the summer was the responsible thing to do. As long ago as 1831, astronomer and statistician Adolphe Quetelet … Continue reading
Friends in low places
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
Performance negated pay
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
Posted in AML, Due diligence, Money laundering
Tagged AML, bonus, due diligence, financial crime, MLRO, money laundering, proceeds of crime, remuneration, risk-based approach, training
Leave a comment
Leak technique
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 AML, disclosure, due diligence, financial crime, ICIJ, International Consortium of Investigative Journalists, money laundering, Offshore Leaks Database, organised crime, Panama Papers, Paradise Papers, PEP, proceeds of crime, research, risk-based approach, tax evasion, white collar crime
Leave a comment
