Archive

After the storm

Hello from a storm-tossed Cyprus. (Yes, it does rain here sometimes, and when it does, it does so with commitment.) After an extraordinary couple of months in British politics, some semblance of normality has returned.

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September 2022

If you're not all over it, then best get your skates on, the first deadline is at the end of October 2022.

Welcome, NPA Members

The National Pawnbrokers Association of the UK is a modern forward thinking Membership Association which helps to promote best pawnbroking practice. The National Pawnbrokers Association has commissioned Lime to prepare outlines for the minimum documents that pawnbrokers must have in place with regards to anti-money laundering specifically. To get these

Lime Consulting

Lime is expert in anti money laundering legislation, regulation and guidance in the UK and EU. We help companies (MSB, FX, Money Transfer, Pawnbrokers, High Value Dealers, Estate Agents) ensure that they have robust polices and procedures to deter, detect and disrupt money laundering and other financial crime. Sign up

AML 4 MSB 14. Review, Test & Amend

The bad guys read the regulations too. They seek out loopholes and weaknesses. When they find one, they exploit it. For this reason, we are constantly reviewing our risk assessments and procedures.

AML 4 MSB 13. Training

All you need to do is whip up a load of uptodate, maintained training materials appropriate to every role in the firm. In case you’d like a hand with that - its kind of right up our alley.

AML 4 MSB 12. Record Keeping

During an audit, or worse, a court case, you do not want to be presented with a policy document from your own firm dated ten years ago, with no evidence that it has ever been looked at since.

AML 4 MSB 11. SAR 2

Tipping off understandably alarms frontline staff. If you’re not careful, you end up with a team terrified to talk to customers. Create sensible guidance for them.

AML 4 MSB 10. Suspicious Activity

More acronyms. Now that you have PEP - it is time to meet your new friend SAR. SAR stands for Suspicious Activity Report. From the guidance: This is the name given to a report sent to the NCA under the Proceeds of Crime Act or the Terrorism Act. The report

AML 4 MSB 9. PEP Talk

Fear not, I'm not going to start shouting. PEP is yet another acronym. Politically Exposed Person. It feels as though the technical detail of the definition is constantly shifting, but the guiding principle is easy enough. From the guidance "Politically Exposed Persons are persons that are entrusted with prominent public

AML 4 MSB 8. Customer Due Diligence (CDD)

It's not an only-child. there's big sister Enhanced Due Diligence (EDD) and baby brother Simplified Due Diligence (SDD) too. We'll get to them later.

AML 4 MSB 7. Risk-Based Approach

You have completed a risk assessment and written policies and procedures to mitigate and manage those risks. Now is the time to get into the specific nitty gritty.

AML 4 MSB 6. People and Liabilities

You must appoint a nominated officer. If you are a sole practitioner, then you are the Nominated Officer. (NO) The NO receives reports of suspicious activity from within the business and deciding whether to report to the National Crime Agency (NCA). The NO needs to be sufficiently senior within the

Merry Christmas

It's certainly going to be an unusual Christmas. We hope that you have a safe and restful time. We're all going to have a lot of work to do in 2021. Marry Christmas and Happy New Year.

AML 4 MSB 5. Policies, Controls and Procedures

Most sanctions and penalties are levied not because a procedure is wrong, but because a firm does not follow its own procedure, or has no procedure at all.

AML 4 MSB 4. Risk Assessment

The risk-based approach. In a nutshell, you must assess where your business is most at risk - in order to plan your mitigation. While some risks are specific to types of business, every business is individual, and so risk assessments will be unique. Put simply, Barclays faces a different suite

AML 4 MSB 3. Senior Managers

Well, as regulation evolved, it became apparent that senior managers felt that The Regulations were an issue for the Compliance department, and nothing to do with them. The definition clarifies that if you have a management role, then you have a responsibility.

AML 4 MSB 2. What is a Money Service Business?

Short version? If you are in scope, get registered. Pronto. By all means get in touch if you want help or advice. It costs nothing to talk.

AML for MSB. 1. What is money laundering and terrorist financing?

While they’re far from perfect, following them, and the guidance that accompanies them, constitutes a defence in court. In short, The Regulations are our friend.

AML 4 MSB. Introduction

Why are we so seduced by acronyms? During presentations, I often start by describing the field of anti money laundering (AML) compliance as “alphabet soup”. “When in doubt, throw an acronym or two about.” It’s the consultant’s creed.

Cyprus Papers Update

The Cyprus Investment Program was closed as of November 1st. The government made all the right noises about launching law enforcement investigations.

The Cyprus Papers (Undercover.)

Atomised. The credibility of the Cyprus government, that is. I wrote six weeks ago [https://www.limeconsulting.com/the-cyprus-papers/] about the papers leaked to Aljazeera.com, alleging that all was not strictly above board with the Cyprus Investment Program (CIP). The government had come out swinging, defending the program, while

Virus-slayer (No, not him)

Incidentally, he was arrested in Barcelona, on his way to Istanbul. Of course he was. The race must be on for the film rights. Johnny Depp as lead?

FinCen 2 Fallout.

I am in the midst of the BigCompFest 2 [https://bigcompfest2020.int-comp.org], a virtual conference. Perfect timing to assess the compliance industry’s reaction to the revelations of the FinCen files. Tim Tyler (TT), Head of Financial Crime at the International Compliance Association [https://www.int-comp.org] (ICA) led

The FinCen Files

Company formation needs reform, across all jurisdictions. It wouldn’t be particularly difficult and there are plenty of experts out there to implement the project. And yet…nobody does. Why is that, I wonder? That’s the question that I would like to see answered.

BigCompFest Part II

Tomorrow, I’m back online, attending a series of webinars put on by the International Compliance Association. This week, we’re covering Leadership and Cyber Risk.

Zoom

Along with many others, I have been on a steep learning curve. Houseparty, Zoom, Google whateveritscalled, Microsoft Teams, I’ve battled through them all. Pre-pandemic, there was no need for these things. Be honest, who wants a video conference with Compliance?

Why Ghost?

I'm a consultant. My product is, quite literally, my time. Time spent on a website is not billable and is therefore an opportunity cost. I would argue that in this field, a website is not a sales tool. Generally, clients do not first find me here. It's a touchpoint, where

The Ghost in the Machine

Lime has migrated from a Managed Wordpress Hosting to a Ghost Pro one. Cleaner and easier for me to manage. A step forward I think. I have made the same move with my personal blog [https://www.stuartlennon.com]

The Cyprus Papers

“[The Cyprus Papers] are a batch of leaked documents obtained exclusively by Al Jazeera's Investigative Unit, containing more than 1,400 approved applications for the Cyprus Investment Programme (CIP) run by the Republic of Cyprus.

Innovation

Necessity is the mother of invention, says the proverb. Lime delivers seminars on AML and regulation. Clients have varying requirements, and previously, I would pull together a slide deck and jump on a plane. Business travel. Remember that? People bringing me drinks on an aeroplane, checking into a nice hotel

Fraud Threats during the Pandemic situation

I wrote last week [https://limeconsulting.com/the-dark-money-files/] about fraud, and the Dark Money Files [https://www.thedarkmoneyfiles.com/], in particular. This week, I caught up with the final presentation on Fraud. Business has adapted to Covid-19. Logically, fraudsters have too. Compliance teams have been completing risk assessments, and criminal

The Dark Money Files

Day three of the Big Compliance Festival was all about fraud. Compliance is seldom considered thrilling or exciting, but fraud is the only element about which movies are made. All three presentations were excellent. Actually, that’s a guess. I have, as yet, only watched two. The third is on

Big Compliance Festival 1. Change and Culture

I survived. Part one of The Big Compliance Festival, that is. All six speakers, including David Blunt from the FCA talked about the importance of culture in compliance. Let me oversimplify this. Regulators and supervisors don’t want to see firms being compliant because they have to be; they want

The BigCompFest

Short for the Big Compliance Festival [https://www.int-comp.org/about-ica/ica-press-room/the-big-compliance-festival/] . I can hear you licking your lips at the thought of it. Run by the International Compliance Association, of which I am a Fellow (get me!) This is an annual event. 2020 will be different. The compliance

Three Wise Monkeys

“€17.8 billion over 5 years. All from non-resident customers. Who are these customers? The database appears to have a few blanks.” “…” “I see. These non-res customers, with complex corporate structures, including Malta, Cyprus, and Luxembourg are shy – and we feel it best to keep their personal data off the

Working Safely during COVID-19 in shops and branches

The Department for Business, Energy and Industrial Strategy (BEIS) has issued Guidance [https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/shops-and-branches] for employers, employees and the self-employed. Purpose “This document is to help employers, employees and the self-employed in the UK understand how to work safely during the COVID-19 pandemic, keeping as

Keeping Up-to-date

2018 was a busy year for Lime. In addition to looking after clients, Stuart got re-certified [https://limeconsulting.com/recertified/] in Anti Money Laundering by the International Compliance Association (ICA) [https://www.int-comp.org] and attended the Annual Conference in London. The ICA runs multiple events, seminars and webinars as

Sanctions: In, out, in, out, shake it all about.

In June, I wrote [https://limeconsulting.com/when-consensus-fails/] about the conflicting advice on sanctions and specifically on dealing with Iran. A couple of months later, the international community will surely have sorted that out. Ah. Not exactly. Federica Mogherini, the EU’s high representative for foreign affairs, said Brussels would

Stop Press. Banks charge fees!

Card Fees. Annually, the BBC recycles a story on foreign ‘plastic’ spending by UK travellers and the fees they pay. The latest iteration was last week. I caught it on the evening news, and at the time of writing, it remains on the internet [https://www.bbc.co.uk/news/

Recertified

Several years ago, I undertook not one, but two diplomas with International Compliance Training (ICT) [https://www.int-comp.com]. First in anti money laundering (AML). I have to admit; it was hard work. Studying I hadn’t done any studying in a long time. If I wanted to know something

De-risking - an epidemic?

I was talking to an estate agent. He was negotiating his exit from his current firm to set up on his own. “All going smoothly?” I asked. “Well, apart from the Bank.” I assumed that the Bank was exercising caution over extending a loan to a new business. “No, they

When consensus fails.

I wrote here in thanks for the antics of “The Donald”, which served as a useful way of engaging an audience that otherwise was less than enthused by AML Compliance Training. However, his new, combative approach to, well, pretty much everything, does undermine the concept of international consensus being at

Donald. Saviour of refresher training?

Next week, I am delivering refresher training to some counter-staff of a MSB. At the start of the session, I ask the delegates for any real of concern or topics that they would like to see covered. Almost certainly, I’ll be swept away by an onrushing tide of silence.

Compliance Frameworks for MSB

The very thought of a compliance framework can be enough to make a SME owner sigh. Regulations are written to cover all sizes of entities, and it can be difficult to work out how they can be applied to a company with very few staff and no departments. Nevertheless, regardless

HMRC MSB Review

More properly, the title is; ‘HM Revenue and Customs AML/CTF Thematic Review of anti-money laundering compliance in the Money Service Business. The report in itself is worth reading, but my interest was piqued by the following; ‘Due to concerns that MSBs may be easily abused by criminals and terrorist

ICT re-certification

In 2017, I bought another, unrelated, business [https://pocketnotebooks.co.uk] It has been, and continues to be, fun. The business has grown, made me laugh, and made me cry. In my experience, that’s a good sign. I have still been working in consultancy, looking after some treasured, long-term,

HMRC wants MSB Customer data

HMRC has issued a consultation document. [https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/548597/Tackling_the_hidden_economy_Extension_of_data-gathering_powers_to_Money_Service_Businesses.pdf] They are looking to extend the scope of existing powers to include MSBs. The data-gathering powers are used to

Ebay. Am I missing something?

In a previous life, I must have been a magpie. I only need to catch sight of a shiny new Apple gadget and I start experiencing palpitations. This week, I decided that I could not justify two Apple laptops. So, I took a deep breath and typed eBay into my

Money Service Businesses and Banks

Here [https://limeconsulting.com/sorry-we-are-closing-your-account/]I posted about the torrid time Money Service Businesses were having hanging onto banking facilities. The difficulties persist. Some businesses have closed, or reverted to older practices, keeping the flow of money hidden, out of the limelight. This latter practice is a spectacular own goal,

Updated Website

We have reviewed our site and updated it. The theme and colour have remained the same – but the content has been updated. For small businesses operating in the regulated or supervised sector, things are not getting any easier. Banks continue to be wary of dealing with MSBs, and the threats

PEP. I despair...

Several people and companies that I know are being driven out of business. They are losing their businesses because the Banks are refusing to allow them bank accounts. The banks argue that in view of the increasingly stringent regulations applied to them, they feel it prudent to avoid business that

National Risk Assessment

In October 2015, HM Treasury and the home Office published the UK’s first money laundering and terrorist financing national risk assessment (NRA). This is an obligation under the obligations of the Financial Action Task Force (FATF), to which the UK is committed. The report is a fairly long read,

Sorry, we are closing your account.

I came across this article the other day. It is by Scott Paul who works for Oxfam. Oxfam on Derisking [http://politicsofpoverty.oxfamamerica.org/2015/12/we-regret-to-inform-you-that-we-must-close-your-account/] It is well worth a read. In case you are pressed for time – I have copied one paragraph below. Though banks should make

Derisking

LIME works with a number of MSBs. As the UK banks have adjusted their appetite for risk, they have made it impossible for many MSBs to continue trading in the regulated sector. Whether one believes that phenomenon is driven by law enforcement, regulators or the banks themselves, the closure of

Banks and the MSB Sector

This article originally appeared in the National Pawnbroker Association [http://www.thenpa.com] magazine in September 2015. Derisking “Derisking” in the Money Service Business Sector. “What is it? What does it mean for my business?” If you are running a business in, or touching on, the MSB sector, then the

New website for LIME

LIME Training and Consultancy are pleased to announce the launch of their new website by Creative Wisdom [http://www.creativewisdom.co.uk/] – a design agancy based in Hampshire.