“Bad News Isn’t Wine. It doesn’t Improve with Age”
September 8, 2020
Sex, Smokes and Slimming Down: Tracking Down Reliable Adverse Media
August 13, 2020
Source of Wealth and Source of Funds: The Enduring KYC Challenge
" There are people who have money and people who are rich" ~ Coco Chanel Introduction During my time as a regulator many moons ago, I remember compliance staff candidly explaining to me the challenges encountered when trying to establish a customer’s source of wealth (“SOW”) and source of funds (“SOF”). Those challenges stemmed largely from regulatory uncertainty as to how far their firm needed.
July 28, 2020
All That is Gold Does Not Glitter: JRR Tolkien “Golden Visas” and Financial Crime Detection
March 17, 2020
Anticipating the Unanticipated: AML Controls and Workplace Disruption
Introduction I remember several years ago, my then workplace was hit with a terrible flu virus. Each week, rows of analysts became ill and disappeared home for over a week. The business was almost paralysed after most of the IT team became ill. It took a few months after before we were able to return to business as usual (BAU).
January 27, 2020
Money laundering and terrorist financing amended regulations
The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (“MLRs”): What You Need to Know for KYC and CDD Introduction The 10th of January 2020 was the official transposition date for the requirements of the 5th AntiMoney Laundering Directive (“5AMLD”) by EU Member States. Putting to one side the UK’s impending departure from the EU, a series of amendments to the Money Laundering,.
January 14, 2020
New KYC and Registry Notification Requirements: Are you Ready?
Register Discrepancy Reporting Summary Introduction There's been much discussion over the last two years about the creation of company registers that were introduced under Articles 30 and 31 of the 5th Anti-Money Laundering Directive (“5AMLD”). These amendments were geared towards improving the level of transparency about and access to information about the ultimate beneficial owners (“UBOs”) of.