Tag Archives: SARs

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 , , , , , , , , , , , , , | 3 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 , , , , , , , , , , , , , , , | Leave a comment

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 , , , , , , , , , , | 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

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

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 , , , , , , , , , , | 6 Comments

Money launder-bling

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

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

Confession is good for the soul

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

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

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

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