The world of AML has changed out of all recognition over the last decade. Old crimes are subject to new laws, professional firms and financial institutions are subject to criminal sanctions and regulatory review as never before. Yet the individual client has virtually no say over what various national governments and their competing departments are doing to their rights and liberties in their name. This blog attempts to address the dilemma posed by the question “Quis custōdiet ipsōs custōdēs?”
Thursday, 20 December 2012
Orange Jump Suits for All?
I think this morning's article from the Daily Mail is bang on. Please feel free to disagree.
Tuesday, 20 October 2009
The FSA's Consultation Paper on Enforcement Financial Penalties Closes Tomorrow
- A new framework in DEPP for determining the appropriate level of financial penalty in enforcement cases, with the intention of improving the transparency and consistency of our penalty-setting process, and increasing penalties in line with our credible deterrence strategy;
- An explanation in DEPP of our approach in cases where a person claims the imposition of a financial penalty will cause serious financial hardship; and
- Amendments to the statement in EG of our policy in relation to publicising our action in criminal investigations.
A link to the FSA's can be found here: http://www.fsa.gov.uk/pubs/cp/cp09_19.pdf
The link to the online response form is here: http://www.fsa.gov.uk/pages/Library/Policy/CP/2009/cp09_19_response.shtml
The deadline for comments is tomorrow, however they usually allow a few days grace.
I'll be one of the talking heads discussing this with an audience in the City later on today. Might see you there!
Tuesday, 15 September 2009
And now for something completely different: Issue No.13!
Image via Wikipedia
IMHO, look out for the first criminal conviction for insider trading, HSBC's £3 million fine for really poor data practice and the changes in personnel that are coming to the FSA.
Please note it doesn't cover the recent fine for Barclay's transaction reporting errors as outlined below.
Ta Ta For Now.