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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
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Blogroll
Tag Archives: source of funds
Grey clouds are gathering
I want to talk about the FATF. First, I think it’s called the “eff-ay-tee-eff” – not “fat-fee” or (occasionally) “faft”. And second, I’m interested in the significance of their grey list (officially, their list of jurisdictions under increased monitoring). Not … Continue reading
The woes of UWOs
Unexplained Wealth Orders are now three years old. Although many would like to see their reach expanded – divorce lawyers are particularly interested – they remain available only in cases involving PEPs or those suspected of serious criminality. And indeed, … Continue reading
Hang on every word
I have been called pedantic, but that’s not strictly accurate. The fact is that I make my living from – and spend much of my leisure time with – words. Most compliance-y people are good at detail: at school we … Continue reading
Posted in Uncategorized
Tagged AML, guidance, guidance notes, legislation, MLRO, Money Laundering Regulations, PEP, source of funds, source of wealth
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Head, brick wall, etc.
I first started designing and delivering AML training in 1996. That’s a full quarter-century ago. And can you imagine how many times I have said, over those twenty-five years, things like “check regularly for PEPs – regulators are hot on … Continue reading
Posted in Uncategorized
Tagged AML, FCA, Financial Conduct Authority, Guernsey, guidance, money laundering, PEP, Politically Exposed Person, regulator, source of funds
5 Comments
Ho-ho-ho and CDD
I am assuming that one or two of you might be at work today, so let us turn our AML minds to an important seasonal matter: conducting CDD on Father Christmas. For this particular individual even the most basic identity … Continue reading
Wimples and wagers
In recent AML training I have found myself talking more and more about the “CDD jigsaw”. As with all jigsaws, the CDD version involves gathering lots of little bits of information – some of which might seem indecipherable or unrelated … Continue reading
Posted in AML, Money laundering
Tagged AML, casino, due diligence, financial crime, Gambling Commission, money laundering, proceeds of crime, source of funds, suspicion
2 Comments
The devil in the detail
I had an interesting phone call with a compliance officer the other day – she will recognise herself in this description. We were talking about a possible suspicion, and I was impressed by both her attention to detail and her … Continue reading
Posted in AML, Money laundering
Tagged AML, compliance, due diligence, financial crime, money laundering, proceeds of crime, source of funds, source of wealth, suspicion
1 Comment
Source for the goose
I am about to shut down for a fortnight’s holiday – my next blog post will be on Monday 18 June – but I thought I would like to leave you with a clever idea to mull. No, it’s not … Continue reading
Do as I say
I’m going to do to you what is often done to me: I am going to tell you my own anti AML story. Actually, it’s an anti anti AML story – you’ll see. In deference to the diktats of the … Continue reading
Posted in AML, Due diligence, Money laundering
Tagged AML, due diligence, financial crime, proceeds of crime, source of funds, suspicion
7 Comments
The test of time
During some AML training last week, someone asked me a question that I am regularly asked, and – despite this (you’d think I’d learn) – I still don’t have a good answer to it. In short, they wanted to know … Continue reading