Tag Archives: source of funds

Grey clouds are gathering

Posted on June 23, 2021 by ihatemoneylaundering

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 →

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The woes of UWOs

Posted on April 21, 2021 by ihatemoneylaundering

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 →

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Hang on every word

Posted on March 10, 2021 by ihatemoneylaundering

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 →

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Head, brick wall, etc.

Posted on January 6, 2021 by ihatemoneylaundering

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 →

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Ho-ho-ho and CDD

Posted on December 23, 2020 by ihatemoneylaundering

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 →

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Wimples and wagers

Posted on December 21, 2018 by ihatemoneylaundering

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 →

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The devil in the detail

Posted on October 8, 2018 by ihatemoneylaundering

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 →

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Source for the goose

Posted on June 1, 2018 by ihatemoneylaundering

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 →

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Do as I say

Posted on February 20, 2017 by ihatemoneylaundering

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 →

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The test of time

Posted on January 28, 2013 by ihatemoneylaundering

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 →

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