Tag Archives: risk-based approach

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 , , , , , , , , , , , | 3 Comments

The cheque less travelled

Posted on July 25, 2018 by

One of the things that enticed me to write historical crime novels focusing on financial crime was the realisation – when I was doing some research into the history of a particular bank – that the specific tools may change … Continue reading →

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

Do unto others

Posted on December 13, 2017 by

The Guernsey Financial Services Commission has been rather busy recently, what with working away on revised AML/CFT legislation and guidance, and now putting out a pair of publications to explain why and how they regulate the Bailiwick’s financial services sector.  In … Continue reading →

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

Big worries about small accounts

Posted on November 15, 2017 by

The news has been full in recent days of the financial activities of the “super-rich” and fiscally sophisticated.  (That’s my phrase, that last bit, but I can imagine it catching on.  Who knows: we might even start talking about the … Continue reading →

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Miffed at MiFID II

Posted on October 4, 2017 by

Fifty-two.  That’s how many triple packs of Jaffa Cakes I could have bought with the £138 I have just had to shell out to buy an LEI for my company.  That’s a Legal Entity Identifier: a 20-digit identifying number required … Continue reading →

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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 , , , , , , , , | 7 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