Tag Archives: SARs

Could do better

Posted on August 25, 2021 by ihatemoneylaundering

One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading →

Posted in Uncategorized | Tagged AML, business risk assessment, CDD, FCA, Financial Conduct Authority, MLRO, PEPs, Regulations, reporting, risk, SARs, suspicion, training | Leave a comment

Just do it

Posted on June 16, 2021 by ihatemoneylaundering

Sportswear and I rarely coincide, but I am a fan of the slogan “Just do it”. Years ago a much-respected older friend gave me his top tip for efficiency: if you think of a job that needs doing and it … Continue reading →

Posted in Uncategorized | Tagged AML, AML/CFT, anti-money laundering, AUSTRAC, bank, CDD, enforcement, financial crime, identification, MLRO, money landering, SARs, training | 2 Comments

Faint at art

Posted on March 31, 2021 by ihatemoneylaundering

It’s a tricky thing, art. No – I don’t mean those arguments over whether an unmade bed or a black painted square is art, but the deliberations about when the art world is part of the AML community and when … Continue reading →

Posted in Uncategorized | Tagged AML, art, art market participant, cash, Fifth Money Laundering Directive, Fourth Money Laundering Directive, High Value Dealer, MLD4, MLD5, money laundering, National Crime Agency, National Economic Crime Centre, NCA, NECC, SARs | 1 Comment

Save our SARs

Posted on October 28, 2020 by ihatemoneylaundering

I am a fan of the philosophy of SARs: I think it is correct that businesses handling client money should be obliged to report to the authorities if they suspect that that money is the proceeds of crime or connected … Continue reading →

Posted in Uncategorized | Tagged AML, banking, Hong Kong, investigation, legislation, money laundering, National Crime Agency, NCA, reporting, SARs, suspicious activity report, terrorist financing | 2 Comments

Latest leak lessons

Posted on September 23, 2020 by ihatemoneylaundering

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”. I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading →

Posted in AML, Money laundering, White collar crime | Tagged AML, communication, corruption, due diligence, Economist, financial crime, government, legislation, MLRO, money laundering, organised crime, Panorama, PEP, proceeds of crime, research, SARs, suspicion, suspicious activity report, white collar crime | 4 Comments

Data doom and delight

Posted on June 24, 2020 by ihatemoneylaundering

With writing a post once a week only (I’ve fallen into writing longer posts less frequently – hope that’s OK), there’s sometimes a bit of a delay until I get round to dealing with something that’s been in the news. … Continue reading →

Posted in AML, Money laundering, Training | Tagged AML, communication, disclosure, due diligence, financial crime, government, money laundering, organised crime, Politico, proceeds of crime, research, SARs, suspicion, tax evasion | 5 Comments

A sprinkling of SAR-dust

Posted on June 17, 2020 by ihatemoneylaundering

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime. Does it shift the burden of investigation from law enforcement to the financial sector? Does it cost much more than it saves? Are … Continue reading →

Posted in AML, Money laundering | Tagged AML, Bank Secrecy Act, communication, disclosure, due diligence, FATF, financial crime, FinCEN, FIU, fraud, organised crime, proceeds of crime, RUSI, SARs, suspicion, suspicious activity report | Leave a comment

This time it’s personal

Posted on March 11, 2020 by ihatemoneylaundering

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 AML, bank, Bank Secrecy Act, due diligence, financial crime, legislation, money laundering, proceeds of crime, risk-based approach, SARs, suspicion | 2 Comments

The plain un-SAR-nished truth

Posted on March 6, 2019 by ihatemoneylaundering

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 AML, disclosure, due diligence, FATF, Financial Conduct Authority, financial crime, FIU, government, National Crime Agency, National Risk Assessment, NCA, SARs, Solicitors Regulation Authority | 8 Comments

Taking task forces to task

Posted on January 16, 2019 by ihatemoneylaundering

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 →