Tag Archives: suspicion

Mind your own business

One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators.  Although this can … Continue reading

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Ethics girls and boys

With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind.  I come from mixed stock: one half of … Continue reading

Posted in AML, Uncategorized, White collar crime | Tagged , , , , , , , , , , | 4 Comments

Latest leak lessons

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”.  I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading

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Friends in low places

For my sins, I start every working day with a trawl of the latest money laundering stories.  As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading

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Data doom and delight

With writing a post once a week only (I’ve fallen into writing longer posts less frequently – hope that’s OK), there’s sometimes a bit of a delay until I get round to dealing with something that’s been in the news.  … Continue reading

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A sprinkling of SAR-dust

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime.  Does it shift the burden of investigation from law enforcement to the financial sector?  Does it cost much more than it saves?  Are … Continue reading

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A most tempting offer

The name of my company is the result of a family joke: my father observed one day that I was always thinking about crime.  I wasn’t sure I’d be allowed to have the name but I was, and it’s memorable … Continue reading

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No, no, no to UWO, UWO, UWO

Most of us in the world of AML have welcomed the advent of the Unexplained Wealth Order – the court order introduced by the Criminal Finances Act 2017, which can be served to compel either a PEP or someone involved … Continue reading

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The topic will be sin and that’s what I’m ag’in

At the beginning of April 2020 the UK’s National Crime Agency published its “National Strategic Assessment of Serious and Organised Crime 2020”.  Of course, much of this report looks at the damage being done by criminals but – as instructed … Continue reading

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Looking to the post-pandemic future

I’m not going to attempt to foretell the impact that the current pandemic will have on our financial systems or on financial crime – there are many people much better qualified than I to do that.  For instance, the tip-top … Continue reading

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