Tag Archives: SARs

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

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Please hold – for six months

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

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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

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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

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Double-duty SARs

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

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

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Cakes and liability

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

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SARs in tiaras

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

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Calling for consent

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

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SARs as information-sharing triggers?

Earlier this week, the head of the National Crime Agency, Keith Bristow, announced that his agency had entered into an information-sharing agreement with the ten largest British banks.  I have tried without success to find an official press release on … Continue reading

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