Tag Archives: suspicion

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

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 2 Comments

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

Posted in AML, Money laundering, Training | Tagged , , , , , , , , , , , , , | 3 Comments

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

Posted in AML, Due diligence, Fraud, Money laundering | Tagged , , , , , , , , , , | 4 Comments

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

Posted in AML, Bribery and corruption, Money laundering | Tagged , , , , , , , , , , , , , , , , , | 2 Comments

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

Posted in Fraud, Money laundering | Tagged , , , , , , , , | 2 Comments

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

Posted in AML, Money laundering, Organised crime | Tagged , , , , , , , , , , , , , | 11 Comments

Planes and pandemics

One of the challenges of AML work is keeping up with the endless adaptability and imagination of criminals.  Unshackled by moral considerations, or by the need to report to risk committees or by the requirement to comply with legislation (quite … Continue reading

Posted in Fraud, Money laundering, Organised crime | Tagged , , , , , , , , , , , | 4 Comments

This time it’s personal

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading

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More Bloody Embezzlement?

Just like police officers, customs officers and passport officers, MLROs find themselves doing a certain amount of profiling when it comes to looking for high risk clients.  We know about certain high risk occupations and high risk nationalities and even … Continue reading

Posted in Bribery and corruption, Money laundering, White collar crime | Tagged , , , , , , , , , | 4 Comments