And so here we are: my final weekly blog post.  I could think of no more fitting topic than my top five tips for MLROs, garnered over twenty-five years of working with you. Get people to care.  It’s all very well reminding staff about the legislation and penalties, about your policies and procedures, but we all know that no-one works to their highest standard unless they care about what they’re doing.  So tell them about people trafficking and drug overdoses and the sale of child pornography and the poaching of wild animals and the theft of state assets and how their tax bills ..read more

As I bring down the curtain on my AML life, I am reflecting in this penultimate post on what I have achieved, the direction my career has taken, and any opportunities missed.  To be honest – and this might come as a surprise to those who know me, and my ever-present Filofax, and my “dish of the day” list pinned onto the fridge every Sunday evening for the coming week – I didn’t have a career plan.  My main skill has always been communication – written and oral – and I stumbled across the subject of money laundering while engaged on another technical writing project.  And reader ..read more

A significant change was made to my AML-ish life on 26 October 2005: on that date appeared the Third Money Laundering Directive, with the addition of “and terrorist financing” to its title, whereas First and Second had been pure money laundering.  I was not convinced at the time that AML and (what has come to be known as) CFT belong together.  The thinking, I suppose, was that they have some elements in common: they both involve those who wish to move their assets around the world without being subjected to too many questions, or without anyone wondering where the value has come from ..read more

As I reach the final weeks of my career in AML, several people have asked me what I will miss the most.  My husband – used, I suppose, to hearing the unvarnished version of events – has also asked me what I will miss the least.  And this is it: explaining to people why money laundering is wrong.  I am perfectly happy to spend time – hours, if needed – explaining why AML is a good idea and why certain businesses are well-placed to spot dodgy money and all the rest.  But I do find it baffling/vexing to have to justify my view that money laundering is bad.  It just is, OK ..read more

You know only too well my views (here and here, for instance) on the ridiculously over-crowded AML supervisory “space” in the UK: we have three statutory supervisors (the Financial Conduct Authority, HMRC and the Gambling Commission) and then 22 “professional body supervisors” for the accountancy and legal professions, which are themselves supervised by OPBAS.  It’s not that I’m opposed to admin – indeed, on a good day, with an episode of “Desert Island Discs” playing in the background, I quite like it – but that I think such a complicated and bureaucratic structure needs to be shown to b ..read more

As some of you may be aware, I am retiring from the world of AML at the end of this year.  In preparation for that I have been having a grand sort-out and have uncovered a couple of things that I commissioned as prizes for my MLRO workshops.  And I thought that it would be a good opportunity to raise some money for charity – specifically, Book Aid International (which “provides brand new, carefully selected books to thousands of libraries, schools, universities, hospitals, prisons and refugee camps around the world”). Accordingly, I have set up two auctions – one for MLRO mugs, and t ..read more

The principle of mitigation is an important one in the justice system.  Once someone has pleaded guilty to an offence – or been found guilty of it after a trial – the attention of the court turns to sentencing, and this is when mitigation comes in (and will certainly be more generous in the former situation than in the latter).  The defence uses all of its skill to urge the judge (or magistrates) to move downwards from the “starting point” sentence, which is – at least in the UK – specified in the publicly-available sentencing guidelines.  And the prosecution usually rebuts thes ..read more

One of the most common requests I have from people commissioning my training is for case studies – stories about money launderers.  And I am more than happy to oblige, as researching these creatures is one of the guilty pleasures of my life.  Take yesterday, for instance, when this headline flashed across my screen: “Mexico’s anti-money laundering chief resigns amid scandal”.  Well, who could resist?  Turns out it might not be anything to do with money laundering – the head of Mexico’s FIU got married and on the private plane he hired to take “influential guests” to his wed ..read more

I know, I know: who thought I would spend my last few months as an AML-er shaking my fist impotently at the madness that is freeports?  But here we are.  I’ve written before (here and here) about why they’re such a bad idea from the point of view of money laundering, and how they will further damage our international reputation (such as it is…) for financial uprightness.  But recently I’ve spotted a few stories that address something more basic, more concrete, more old-fashioned if you will: the physical security of freeports (and customs warehouses and bonded warehouses).  ..read more

Apologies for the unexpectedly long silence: I was felled by covid.  Thankfully I am on the mend and once more have enough energy for outrage and indignation. I had a Dutch boyfriend for several years, during which time I developed a liking for salty liquorice and an extremely limited Dutch vocabulary.  One phrase he did not teach me was Verwijzingsportaal Bankgegevens, but isn’t it marvellous?  It’s the Dutch Bank Data Retrieval Portal and since 1 January 2020 all Dutch banks have been obliged to connect to it.  Well, not all of them: according to Article 32(a) of the Fift ..read more