Tag Archives: SARs

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 →

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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

Credit where credit is due

Posted on March 14, 2016 by

I’m about to get onto my soap-box again, so you have been warned.  Last week I mentioned the recently-published INCSR 2016, with its summaries of jurisdictions of primary money laundering concern.  In a comment on that, a Guernsey reader has … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , | 4 Comments

Double-duty SARs

Posted on November 23, 2015 by

Ever since some hunter in ancient times pulled back his slingshot and managed to kill two birds with one stone, we humans have loved achieving two (and if possible more) ends with one action.  For instance, it is helpful to … Continue reading →

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Running scared

Posted on November 6, 2015 by

Over lunch yesterday, a friend of mine told me a story so bizarre that I have to share it with you.  But for reasons that will become obvious, I have to keep it all anonymous.  My friend’s sister lives in … Continue reading →

Posted in Money laundering | Tagged , , , , , | 7 Comments

Cakes and liability

Posted on June 1, 2015 by

Apart from it being the first day of summer (and it’s still perishing), today heralds the coming into force of the part of the Serious Crime Act 2015 which amends section 338 of the Proceeds of Crime Act.  (I know, … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , | 2 Comments

SARs in tiaras

Posted on May 26, 2015 by

I love FIUs, you know I do.  But they do vary enormously in how they interpret (or, perhaps more realistically, can persuade the holders of their government purse strings to interpret) FATF Recommendation 29 that (my emphasis) “Countries should establish … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 3 Comments

Calling for consent

Posted on March 10, 2015 by

You know what a stickybeak I am – if anyone asks, even very quietly, for an opinion on anything to do with money laundering or AML, I’m in there.  At the moment the UK government is running a very low-key … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , | 1 Comment