Tag Archives: risk-based approach

Calculators at the ready

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

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

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

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

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

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?

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

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

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

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