Blog

Who is my client?

” Who is my client? “ This is a seemingly simple question which was the subject of a lot of discussions at the 12th ACAMS conference in London this Tuesday and Wednesday. “Who is my client?” Simple question? Not so simple, let’s look more closely! In SMEs , we often say that the customer is the…

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ACAMS 12th Annual Meeting in the shadow of the Big Ben

The great party of the AML, ACAMS 12th Annual Meeting closed its doors last night and calm fell on the QEII Centre in Westminster. We were nearly 200 participants looking for an empty spot to sit down and listen to a particular speaker (male and female!), crossing paths at the buffets and wringing our necks…

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Terrorists attacks: what is our responsibility?

Paris, 13 November 2015: 130 dead. Brussels, 22 March 2016: 32 dead. Not including the injured, of which many will suffer lifelong consequences. What is the responsibility of each of us concerning these attacks? The question is out there. First of all, there is the responsibility of the common people (the neighbours, family and friends,…

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The Transparency International list has been updated

Over the last few days, Transparency International has updated their Corruption Perception Index for 2015. Who is Transparency International? Transparency International was founded in 1993. TI is an international NGO that collects the most recent information concerning corruption in countries all over the world and highlights the poverty and inequality corruption leads to. A quest…

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The Domiciliation Law and its measures AML/CFT 

A quick reminder: a judgment by the Court of Appeal in Luxembourg on 16 December 2015 raised some very interesting questions regarding the Domiciliation Law. Among the questions brought up, there was one regarding the respect of the Law of 31st May 1999 on domiciliation. The judges went back to the parliamentary debates that preceded…

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The Fight against Money Laundering in France: The 2015 Report

The French Ministry of Economy and Finance published a thought-provoking report about the fight against money laundering in France. It highlights the numbers and facts and looks at the penalties that were charged in 2015. The Commission nationale des sanctions (CNS) gives an impressive insight about the penalties that may incur. Furthermore, the activity report gives you…

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The 4th Directive: the newly targeted employments

The 4th Directive clearly outlines the employments and activities that are now targeted by the second article. It is important for those newly-targeted professions to quickly adapt to the changes. Generally speaking, every activity which is practiced by a qualified person and refers to a transaction with a client that wasn’t associated with the person…

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Terrorism financing : what we learned from recent events

Recent events have unfortunately pulled terrorism and terrorism financing back up our list of concerns. We all talk a lot about the events that occurred, each with our own analysis of how we got to where we are, but very little is said of the financing of terrorism per se, and of its sinister henchmen….

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The 4th Directive for dummies

Using a title like this one: “The 4th Directive for Dummies” is obviously meant to provoke ! That’s just my intention. In general, this blog deals with subject matters that can be quite tedious, so a few tongue-in-cheek comments here and there can’t hurt. The 4th Directive : where are we coming from ? The…

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For the entrepreneur’s peace of mind !

It’s an occurrence observed daily: the peace of mind of an entrepreneur is constantly eaten at by all the responsibilities that keep being piled onto him. Be it in the courts of law, in the economy, or in the media, it is becoming common-place to blame an entrepreneur for what he has done, what he…

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