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Howdy, and welcome to my blog. If you'd like to get instant updates whenever I've been inspired or irritated enough to write something, please do subscribe.The day job
When I'm not writing this blog, I'm doing AML training, writing, research and advice. Obsessed? Hell, yeah! To find out more, have a look at my website.-
“The Solo Squid: How to Run a Happy One-Person Business”
“Heir Apparent” – the sixth Sam Plank novel
FREE Official Guide to the Sam Plank Mysteries – sample chapters and glossary
New e-boxset of first three Sam Plank e-books! Click image to buy…
“Faith, Hope and Trickery” – the fifth Sam Plank novel
New piggy in the sty! This one is for UK estate agents
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Recent posts
Collection of columns: “Susan in the City: The Cambridge News Years”
“Portraits of Pretence” – the fourth Sam Plank novel
Sam speaks! New audiobook of “Fatal Forgery”
“Worm in the Blossom” – the third Sam Plank novel
AML for NEDs in five editions: Guernsey, Isle of Man, International, Jersey and UK
AML books for UK staff
AML books for Guernsey staff
AML books for Jersey staff
AML books for Gibraltar staff
“The Man in the Canary Waistcoat” – the second Sam Plank novel
“Fatal Forgery” – the first Sam Plank novel
Edward’s adventures now out in 6-part e-format
Another good read
Posting dates
June 2023 M T W T F S S 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Categories
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Blogroll
Tag Archives: SARs
Could do better
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
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Just do it
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
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
Save our SARs
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
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
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
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
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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 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
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
Taking task forces to task
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 AML, communication, Economic Crime Strategic Board, financial crime, government, HM Treasury, Home Office, money laundering, research, SARs, task force
6 Comments