Welcome
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.“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
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Blogroll
Tag Archives: SARs
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
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
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 AML, communication, due diligence, legislation, MLRO, money laundering, SARs, suspicion, training
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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 AML, due diligence, financial crime, Gambling Commission, government, ML Regulations, money laundering, proceeds of crime, SARs, suspicion
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 AML, due diligence, financial crime, FIU, legislation, MLRO, publications, SARs, suspicion
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 ELMER, National Crime Agency, NCA, proceeds of crime, reporting, SAR, SARs
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A welcome mat for money launderers
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 AML, asset forfeiture, due diligence, financial crime, government, legislation, proceeds of crime, Proceeds of Crime Act, SARs
1 Comment
Credit where credit is due
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