Tag Archives: source of wealth

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

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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

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Great-grandpapa’s billions

Like many of you, I have been reading “Kleptopia” by investigative reporter Tom Burgis.  It’s both wonderfully well-written and terrifically depressing.  If there’s a British PM in the past twenty years who hasn’t been advising foreign kleptocrats on how to … Continue reading

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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

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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

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Anna Karenina and the assault rifle

PEPs = high risk = EDD.  But why?  The short answer is corruption: anyone with access to public influence and/or public money will be a target for criminals who want to gain that access for themselves.  Of course, the majority … Continue reading

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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

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