Tag Archives: sanctions

Name and shame

We’re all used to lists and databases.  There are sanctions screening systems and PEP screening systems.  Within their organisations, MLROs have access to client databases.  And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership … Continue reading

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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

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No escape for NY compliance officers

Ever since it burst onto the regulatory scene in 2011, the New York Department of Financial Services has specialised in ruffling feathers.  In August 2014 they stepped out of line with all other regulators (who were considering a united approach) … Continue reading

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Sanctions go super-sonic

It’s funny, anti-money laundering training.  You notice a new topic and you start to include a couple of slides about it – people are a bit bemused, but being lovely polite delegates they let you get away with it.  Then … Continue reading

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