Tag Archives: SARs

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

The plain un-SAR-nished truth

Posted on March 6, 2019 by

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS?  “Ruthless trained killers are just a … Continue reading →

Posted in AML, Money laundering, Organised crime, Supervision | Tagged , , , , , , , , , , , , | 8 Comments

Taking task forces to task

Posted on January 16, 2019 by

May I be honest with you?  I have worked alone for more than twenty years and I like it, I really do.  As an only child I became used to not having to compromise, and I also have a visceral … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 6 Comments

Money launder-bling

Posted on September 19, 2018 by

Working in Guernsey this week, I was talking to a client about the concept of the High Value Dealer (under local legislation, those who “[trade] in goods where there is received… a payment or payments in cash of at least … Continue reading →

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Confession is good for the soul

Posted on May 9, 2018 by

Today’s question: in what way is an AML trainer like a Catholic priest?  Let me set the scene (which I shall keep deliberately vague, for reasons that shall become obvious).  Some time ago I was invited in to see a … Continue reading →

Posted in AML, Money laundering, Training | Tagged , , , , , , , , | Leave a comment

A rap on the online knuckles

Posted on January 8, 2018 by

AML regulation of the gambling sector in the UK is complicated; even I (writing as an AML obsessive) am sometimes confused about who is in and who is out.  However, one sector that is most definitely in is online gambling, … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , , | 4 Comments

Measuring the uncountable

Posted on July 5, 2017 by

One of the hardest aspects of any AML regime is measuring its effectiveness.  A bit like insurance, it’s trying to quantify what might have happened if you hadn’t had it.  (That sounds like a nightmare sentence from the translation paper … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , | 5 Comments

Paying the piper

Posted on November 25, 2016 by

On 16 November 2016, the UK government’s Home Affairs Select Committee concluded its examination of the UK’s proceeds of crime regime by publishing the government response to the fifth report of the committee in the form of an appendix to … Continue reading →

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

Please hold – for six months

Posted on October 28, 2016 by

The Criminal Finances Bill is out, described in the Home Office press release as “legislation to tackle money laundering and corruption, recover the proceeds of crime and counter terrorist financing”.  When it was at the consultation stage, I responded – … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , | 5 Comments

A welcome mat for money launderers

Posted on August 30, 2016 by

For some months, a Home Affairs Select Committee of the UK parliament, under the chairmanship of Keith Vaz MP, has been taking evidence about the effectiveness of the UK’s proceeds of crime regime.  It has not been a happy story, … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , | 1 Comment