ARTICLES
Dealing with PEP's in the UK
As a result of International Anti-Money Laundering efforts, increased attention has been placed on PEP’s. This is reflected in the revised JMLSG Guidance and the Third Money Laundering Directive (“the Directive'”), which came into force last year and which the UK will have to implement by December 2007. Read more
Ben Hur pools the mass of crime statistics together and comments on why MLROs and Financial Crime Fighters must think more seriously than ever before about financial crime in 2007
If we put the widely published statistics together to see what the picture looks like, is it really that bad, is it cause for concern, do we the custodians of the AML and fraud world need do anything different. Read more
MLRO’s and Disaster Recovery – are you prepared?
The MLRO role and Disaster Recovery (“DR”) do not always go hand in hand, there are of course the smaller firms whose CF11 is also the CF10, and for them it should be done and dusted but even then, have you really thought of everything? Read more
The Compliance Monitoring Plan (“CMP”)
Its December 2005 and the perfect time to think about your Compliance Monitoring Plan 2006, here are some ideas to think about. I have purposely drafted this article for December publication, how many uses does your CMP have? Read more
MLRO’s and the MLRO Annual Report to Senior Management (“AR to SM”)
The AR to SM is a regulatory requirement, it is common practise however to submit the report more frequently than annually, I have heard of many methods as to how other firms meet this requirement. An MLRO has to assess a firms risk, then decide the appropriate way in which to achieve compliance with this requirement. Read more
CCL Partnership comments
In January we saw some quite significant changes to the Anti Money Laundering and the Combating the Financing of Terrorism regimes in the UK. More commonly know as AML and CFT. Read more
Ernst and Young AML Newsletter
Broken Link. Read more
Approved Persons and remaining competent, from an MLRO’s prospective
Well there are several ways to achieve this, certainly the size of your firm, team, resources and internal structure can dictate your abilities in this area, my experience has shown me that some firms deem an approved person competent from a business prospective, but not necessarily from an Ant Money Laundering prospective. Read more
Ben Hur asks Assistant Compliance Officer and KYC Builder “Karen Aghayere” to advise how she resolves some of her KYC issues and what web sites help.
Customers are defined in this context as ‘applicants for business’. This includes any natural, legal person, firm, business or institution who seeks to enter into a business relationship or conduct a one-off or series of transactions, with a firm, as principal or as an agent for someone else. Read more
A Note on the Court of Appeal’s judgment in K Ltd v NatWest
The recent decision of the Court of Appeal in K Ltd v National Westminster Bank Plc [2006] EWCA Civ 1039 considered the anti-money laundering provisions of the Proceeds of Crime Act 2002 ("POCA"), what a bank's obligations are when requested by a client to transfer funds which are suspected to be the proceeds of crime, the definition of suspicion and the courts' powers to order the bank to make a payment out of a customer's account. Read more
AML Alert Newsletter
AML Alert Newsletter 07/06 Read more
“What is “Computer Forensics” and why do Compliance Officers & MRLOs need to know about it?”
Computer Forensics is: the acquisition, analysis and presentation of information from digital devices – to legal standards of evidence, if necessary. Read more
Ben Hur asks solicitor Ed Sautter about the importance of Records Management, such an important area for MLRO’s.
Records management describes the procedure by which an organisation manages the "life cycle" of each of its significant records, from creation, through active use, to archiving and, finally, destruction. Read more
Keith Laurence. An MLRO's view of a money laundering case.
In 2005 I was the MLRO at the London Branch of XY Bank. This institution would prefer to remain anonymous, hence the assumed name. The role there was challenging as there were numerous retail and private accounts as well as corporate ones. Read more
Senior Management Responsibilities (AML)
Since the implementation of the Financial Services and Markets Act 2000 (FSMA), the area of senior management responsibilities has been put under the spotlight. Read more