“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 19, 2020
Transaction Monitoring and Governance: A Cautionary Tale
" I see you have the machine that goes ‘ping’ “
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.
August 5, 2020
Registers, Transparency and Beneficial Ownership
“There is nothing more deceptive than an obvious fact” -Arthur Conan Doyle
July 28, 2020
All That is Gold Does Not Glitter: JRR Tolkien “Golden Visas” and Financial Crime Detection
Introduction It’s hard to believe that it was more than two years ago that the final version of the 5th Anti Money Laundering Directive (5AMLD) was published in the Official Gazette in the European Union.
June 30, 2020
KYC Reviews: The Dragon of AML Compliance Programmes
“It does not do to leave a live dragon out of your calculations, if you live near him.”
June 11, 2020
Acting on adverse media: A tightrope walk for AML/CFT regulated businesses
“We are drowning in information but starved for knowledge” ~ John Naisbitt
April 16, 2020
Life after lockdown: A 4 step checklist to a more efficient remediation
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,.
