Tag Archives: suspicion

Could do better

Posted on August 25, 2021 by ihatemoneylaundering

One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading →

Posted in Uncategorized | Tagged AML, business risk assessment, CDD, FCA, Financial Conduct Authority, MLRO, PEPs, Regulations, reporting, risk, SARs, suspicion, training | Leave a comment

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 →

Posted in Uncategorized | Tagged AML, CDD, Criminal Finances Act 2017, Mansoor Mahmood Hussain, MLRO, money laundering, National Crime Agency, NCA, source of funds, source of wealth, suspicion, Unexplained Wealth Order, UWO, Zamira Hajiyeva | Leave a comment

Mind your own business

Posted on March 17, 2021 by ihatemoneylaundering

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 →

Posted in Uncategorized | Tagged AML, annual report, Board, directors, FCA, FIU, guidance, JMLSG, MLRO, money laundering, nominated officer, reporting, SAR, suspicion | Leave a comment

Ethics girls and boys

Posted on September 30, 2020 by ihatemoneylaundering

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 AML, communication, due diligence, ethics, financial crime, fraud, money laundering, research, risk-based approach, suspicion, training | 4 Comments

Latest leak lessons

Posted on September 23, 2020 by ihatemoneylaundering

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 →

Posted in AML, Money laundering, White collar crime | Tagged AML, communication, corruption, due diligence, Economist, financial crime, government, legislation, MLRO, money laundering, organised crime, Panorama, PEP, proceeds of crime, research, SARs, suspicion, suspicious activity report, white collar crime | 4 Comments

Friends in low places

Posted on July 15, 2020 by ihatemoneylaundering

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 adverse media, AML, due diligence, financial crime, MLRO, money laundering, proceeds of crime, reputation, risk-based approach, suspicion, white collar crime | 2 Comments

Data doom and delight

Posted on June 24, 2020 by ihatemoneylaundering

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 AML, communication, disclosure, due diligence, financial crime, government, money laundering, organised crime, Politico, proceeds of crime, research, SARs, suspicion, tax evasion | 5 Comments

A sprinkling of SAR-dust

Posted on June 17, 2020 by ihatemoneylaundering

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 →

Posted in AML, Money laundering | Tagged AML, Bank Secrecy Act, communication, disclosure, due diligence, FATF, financial crime, FinCEN, FIU, fraud, organised crime, proceeds of crime, RUSI, SARs, suspicion, suspicious activity report | Leave a comment

A most tempting offer

Posted on June 10, 2020 by ihatemoneylaundering

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 AML, disclosure, due diligence, financial crime, fraud, money laundering, proceeds of crime, research, suspicion, Thinking about Crime Limited, white collar crime | 5 Comments

No, no, no to UWO, UWO, UWO

Posted on April 29, 2020 by ihatemoneylaundering

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 →