The point of this blog when I started it was to create an online diary of my life as an AML consultant, specialist, practitioner and enthusiast.  It was intended as a light-hearted alternative to the other more serious pages of this website, with observations, comments, hints, links and thoughts - I hope you've enjoyed it.  And if you have any comments, please do email me - I'd love to hear from readers.

And if you're into historical research, you can find my previous blogs on the Blog 2006 page, the Blog 2007 page, the Blog 2008 page, Blog 2009 page and the Blog 2010 page.

However, I have come to realise that these pages - although written (and I hope read) with pleasure - no longer deserve the name of "blog", as they do none of the features now considered standard for blogs.  So to see my new super-whizzy blog, sign up to emails and take part in polls (get me!), take a look here.  I will leave these pages here, for old times' sake, but my new thoughts - hopefully augmented with your responses - will be appearing in my new blog.  See you there!

Click here to go to Susan's new blog - which started on 3 July 2011 and has taken over from this page.

Friday 1 July
Hooray, hooray - there's a Bribery Act today.  But listening to Vivian Robinson QC describing it so perfectly, eloquently and clearly on Radio 4 this morning, I am once again spitting chips at the dithering incompetence of our government.  Months and months ago they announced that huge changes would be made to the FSA, the SFO and SOCA - without deigning to specify what those changes might be.  Endless weeks of uncertainty, peppered with alarming rumours, have ensured that the brightest and the best from these agencies have - quite rightly - looked for opportunities elsewhere.  Among them is the wonderful VR QC, who has joined an international law firm.  This is governmental short-sightedness on a par with that of Mr Magoo.  And look at the trouble he got into.

Wednesday 29 June
Phew - they're coming thick and fast now.  (My grandfather used to say that his marriage was like that: he was thick and she was fast...)  The FATF has issued a consultation paper on corporate transparency, and I just have to have my say about that as well.  Perhaps all these agencies think that by asking for our views over the summer, we'll all be away or too hot to think, but they underestimated me!  Ask for my opinion and it almost pains me to withhold it.

Monday 27 June
One down, one to go: I've told HMT what I think about their proposed changes to the Regulations, and now I'm going to have a word with the FSA about their proposed AML guide for businesses.  Isn't it nice to be asked?

Thursday 23 June
I had a lovely email the other day, from a lady I have never met in America, saying that she enjoys my website and my "refreshingly honest" approach to AML.  As I sometimes fear that my ramblings in this blog are simply going out into the ether - although admittedly it's much cheaper than therapy - it is a thrill to know that like-minded people are reading them.  I do try to stick to my original intention: to make life a little bit easier for MLROs and other people trying, often in the face of adversity and a seemingly unstoppable tide of money laundering, to do their very best to fight the good fight.  Charlene, thanks again for getting in touch.

Monday 20 June
Money laundering used to be such a nice little subject - entirely manageable, for the unhealthily obsessed such as myself.  But in recent months it has spread its tentacles alarmingly, into sanctions and bribery and corruption and more.  I really want to keep up to date with it all, and have my say on all consultations and enquiries, but the sheer weight of information is in danger of getting beyond me.  I think I need to take a deep breath, turn off the phone and computer, and just read for a few days.  If only!

Sunday 12 June
Isn't it always the way?  Quiet for weeks, and then I go away on holiday and the UK government publishes some incendiary thoughts about the AML regime and proposals for the new National Crime Agency.  I don't think they were too scared to suggest these things on my watch, but you have to wonder...  I shall of course be responding in detail to all proposals - I may be a one-person company, but I have enough opinions for a multi-national corporation!

Thursday 2 June
Well, that week slipped past under the radar, and I have one of those "to do" lists that seems to repopulate itself overnight.  That's the trouble with holidays, isn't it - they need such a lot of forward planning.  Do you remember when you were a child and your parents did all that preparation for you - all you had to to was look forward to it and wake up on the day in a state of advanced hysteria?  That said, this break has been a long time coming, and I am going to enjoy every single second of it - I'm not taking a phone or a laptop or even my Filofax.  Scary!

Friday 27 May
Yet another bank holiday is upon us!  I shall take the opportunity to figure out why my accounting spreadsheet is not showing what it should (I'm hoping it's an Excel rather than an earnings problem) and to sift through another half-dozen of my over-crowded files of articles, some of which now pre-date Al Capone (well, nearly).  A fun-packed day, I am sure you will agree.

Wednesday 25 May
You will be relieved to hear that I have come over all zen.  My website is still playing up, but I have decided to let it do what it wants.  The Icelandic ash cloud may or may not disrupt my holiday flights and my upcoming trip to Guernsey - it's in the lap of Thor and his mates.  And I have given up trying to report on every nuance of who is issuing sanctions against whom.

Monday 23 May
I am in the seventh circle of technical hell.  My email is now working again, but my website has gone doolally.  I am not sure what is going on - when am I ever? - but some pages of my website have slimmed down in a manner that would be much envied by dieters.  It's nothing I've done, but all of a sudden they are skinny rather than spreading across the screen.  After two fruitless hours trying to sort it out yesterday, I have decided to ignore them and hope that they fatten up of their own accord - I seem to manage it effortlessly myself, so why shouldn't they?

Thursday 19 May
Is there anything more infuriating than email that does not work as it should?  I am in Jersey at the moment, and although the hotel has wifi and I can keep up with important Internet developments (the lechery of Strauss-Kahn, the end of season sale at Hotel Chocolat, etc.), my email system has gone into spasm.  I can receive both personal and work emails.  I can occasionally send personal emails, depending on, oh, the tides or something, and I can never send work emails.  So if you're waiting to hear from me, it'll be tonight when I get home.  Via Hotel Chocolat, of course.

Saturday 14 May
A Saturday?  Yes, well, it's the FA Cup final on telly, and work seems as good an excuse as any to make my escape.  Sometimes "I run my own business" is the perfect excuse to get out of things I don't want to do - dinner parties with people I don't really like ("I'd love you, but unfortunately I am running a workshop the next day and with it being just me, I have to get an early night to be fresh") or weekends at the in-laws ("What a shame - but I'll be in Guernsey the week before, and with it being just me, I'll need to catch up on admin at the weekend").  Now, I'm trusting you not to tell anyone about this, otherwise my cover is blown.

Tuesday 10 May
I have been looking closely at how I spend my time, and at least an hour a day is spent updating my information - this website, my e-newsletter, my company Facebook page.  I enjoy doing it, as it is a good discipline and gives me an excuse to read all the latest ML news, but it is time-consuming.  Columnist James Delingpole said recently that he has had to wean himself off FB and Twitter, as it takes too much time and earns him no money.  It is a worry that we might all spend so much time gathering information that we leave ourselves no time to do anything with it!

Friday 6 May
I tell you, keeping up with comment on the likely significance, impact and outcome of the Bribery Act is turning into a full-time job.  Apparently this is the way to get people to sit up and take notice: threaten to send the directors to prison for ten years.  Perhaps we should have done this years ago with AML legislation.  There have been more articles, blog, opinions, webcasts and white papers on the Bribery Act in the last month than I have ever seen on PoCA and the ML Regulations put together.

Tuesday 3 May
It has taken me four hours - four hours! - of wandering around small Portuguese towns to find a wifi, and all so that I can keep my website up to date!  I just hope someone is reading it after all that...  Mind you, sitting in the sun beneath orange trees, sipping a cold Coke while looking out at mountains - it's not all bad.

Thursday 28 April
Hooray, hooray - it's a wedding holiday!  That said, it is mighty difficult to get any productive work done when every email bounces back with a message that the recipient has taken advantage of all the bank holidays and will not be back at their desk until 2014.  If I were a criminal, this is the weekend I would choose to do my most devious laundering...

Tuesday 26 April
You know you've been on holiday too long when you have to check the BBC website to find out what date it is!  This run of bank holidays is a boon for children and teachers, and probably for people who hate their jobs in the financial sector, but personally I'd rather have them spread throughout the year.  But I don't want to sound churlish: I did enjoy sitting in the sun in the garden reading about the dark exploits of the Neapolitan mafia.  (Which made me think: whatever happened to that stripy Neapolitan ice-cream?  Did it go the un-trendy way of raspberry ripple?)

Thursday 21 April
I have become quite addicted to the blog of an American lawyer called Howard Sklar (http://openairblog.wordpress.com/about/), who has been writing a lot recently about the Bribery Act.  And in a recent post, this man of obviously towering intellect and superb taste said this: "Let me talk for a moment about training methods.  Live is good.  Everything else sucks.  Yes, everything.  Conference calls don't work.  Certainly e-learning doesn't work.  And by 'doesn't work', I mean that it doesn't stand a snowball's chance in hell of actually changing behaviour.  There's just no substitute for live training."  Howard, I salute you.

Tuesday 19 April
It has finally happened: one of my lever-arch files (the one labelled "Bad people", actually) was so full that it burst.  So I have spent a few hours this weekend going through my paper files, culling the pieces that are just too historical ever to be of any use.  It is surprisingly hard to get rid of some - especially those dating from when I first discovered the wonderful world of AML - but I have been fierce.  Of course, you can get (almost) everything online now, so in future it will be my computer's lever-arch files bursting at the seams.

Friday 15 April
You can gauge the state of a small business by its three-tray system: in, out and pending.  If I'm overworked, the in tray dominates, and if I've been super-efficient, the out tray is bulging.  But at the moment the pending tray is leading the pack - and through no fault of my own.  The majority of my current projects are waiting for input from someone else - the client, the government, the accountant.  It's a strange situation, but oddly enjoyable to be able to say, well, I might as well just sit back and read this book (on the mafia, since you're asking) as there's nothing I can do until I hear from X, Y or Z.  It's a licence to laze!

Tuesday 12 April
May you live in interesting times, as the Chinese curse goes.  I had originally thought that the Bribery Act was something of a snooze-fest, but as more comments come out and the blogs ramp up a gear, it's actually rather fascinating.  I do like to see tough legal and compliance minds wrestling with it - it's comforting to see that other people are as concerned with the minutiae as I am.  And as if that wasn't enough, the sanctions keep coming.

Friday 8 April
I am still on a high after yesterday's MLRO workshop.  It was so lovely to see all those familiar faces - including one lady who has attended all five of my MLRO workshops.  One of the very nicest things about building a business is the relationships that develop over the years.  I'm about to go through the workshop feedback, so fingers crossed that the sixteen MLROs had as good a day as I did!

Tuesday 5 April
I am starting to feel persecuted.  My workshop on Thursday has a session on sanctions, and almost from the very second I sent the slides to the printer, both the UK and Guernsey governments have had a field day issuing new sanctions.  And then today the GFSC put out a new Instruction.  Don't these institutions realise the havoc they cause?  Grrrr!

Monday 4 April
I tried and tried to think of a good joke to put on this website on 1 April, but no luck.  Unless you count the peculiarly unhelpful guidance on the Bribery Act - except that it's no joke.  There is a little more detail, granted, but the big questions remain unclear: who is covered, and what procedures are adequate?  The answer given in both cases is: it's up to the courts to decide.  Personally, I'd rather know before stepping into the courtroom...

Thursday 31 March
It's here - it's here!  But sod's law dictates that I am in London yesterday and today and don't have time to read all about it.  So everyone in England will know more about it than I do until the weekend.  I even borrowed an Evening Standard from a nice man on the train yesterday, but the article had been written by a four-year old with minimal understanding of it all.  So patience is required - although I did spot that implementation is 1 July and not September, so yah boo sucks to you if you think they're bothered about the summer hols.

Wednesday 30 March
Where is it?  Where is it?  Where is it?  Hot gossip from the Ministry of Justice suggests that the Bribery Act guidance will be published today.  This means that the Act could come into force in late June, but apparently the government is suggesting 1 September instead, so that no-one can accuse them of taking advantage of the summer holidays to sneak stuff in.  As if!  But back to my original question: where is it?  Where is it?

Monday 28 March
I hope I don't fall at the final hurdle.  I now have a large box of folders, carefully assembled and packed using yards of sticky tape.  And I need to get it to the local post office - which is much less local than it used to be, thanks to a ferocious cull of local branches.  So I have to hope that I can balance this 10kg box on my bike basket as I wobble my way across town.  And who said that working in the finance industry wasn't glamorous?

Friday 25 March
And today I have the task of assembling the workshop folders.  I have to concentrate, otherwise some delegates get more pages than others, and regular attendees at these workshops know that the printouts often come with cat paw-prints, courtesy of my furry office manager.  Then it's off to the post office.  (I used to use ParcelForce, until I realised that first class post is half the price - postage pricing is a dark art, second only to airline pricing.)  Now, where did I put that hole-punch?

Tuesday 22 March
I just love doing workshops - and particularly my advanced workshops for world-weary MLROs - but I can't tell you what a relief it is when I finally finish preparing a new one and drop the material at the printers.  It's now all too late: there's nothing I can change or add, and now I just have to hope that I've got it right and the MLROs enjoy it.

Monday 21 March
Time is accelerating: I've just received my Filofax diary for 2012, and my sister-in-law asked yesterday what we're doing for Christmas.

Thursday 17 March
I really don't understand the taxi business - how it works, what the controllers are saying on those squawky boxes, why they all want to smell of pine trees.  I have used lots of pre-booked taxis in the last fortnight, and of the eight journeys I took, the drivers were late for five of them - the worst by thirty minutes.  I don't ask much of a pre-booked taxi - I'm not insisting on velvet cushions or silver salvers of Maltesers - but the one thing I do want, and the whole point of pre-booking, is an on-time departure.  I would also like to request a taxi driver who does not moan about the English (our footballers, rugby players, politicians or monarch).

Thursday 10 March
In theory, airports should be wonderful places.  Full of food and shops, big windows, bustle and activity.  In reality, they are terrible - with wifi that doesn't work, tables available only if you're eating, nasty mass-produced and reheated food, and not enough seats near the gates.  Can you tell that I'm in a travel grump?

Monday 7 March
Keeping up with all the collapsing regimes - and former leaders charged with all sorts of financial irregularities - is tricky.  I have decided to stick to my usual policy: report on the charge only if it is particularly high-profile or unexpected, but in general report only on the conviction.  On the bright side, I'll have no shortage of colourful case studies for future training!

Wednesday 2 March
Ooo, a moral dilemma!  My husband is in hospital, and in the main reception there is one of those market-stall type sellers, selling big brand cosmetics and toiletries at heavily discounted prices.  Normally I steer clear, as I figure that such bargains can only be (a) counterfeit, (b) stolen, or (c) out of date - all of which are illegal, of course.  But surely if it's on NHS premises, some sort of fit and proper check has been done...?  I haven't succumbed yet, but I may have to ask the seller whether it's (a), (b) or (c) - luckily there'll be lots of First Aiders around when he thumps me.

Monday 28 February
I am not really a political animal, but I am finding it fascinating that all of the Middle Eastern regimes that are toppling like dominoes are choosing to go the financial route to hurt their ex-leaders.  Dictators are finding their assets frozen and their ministers under investigation for money laundering.  I assume (and in some cases, hope) that war crimes and genocide charges will follow, but it is interesting to see that the money laundering provisions are a handy way to halt these people in their tracks.

Thursday 24 February
I've just been caught in a circle of news!  I put a story on the Stop Press page of this website on Monday.  And yesterday I received an email from a client, who had received it from a client of his - and it was my news story cut and pasted into the email!  Reminds me of the children's book "What Katy Did", where schoolgirls put the word "marigold" into every essay they wrote, to check whether the teachers were reading them - I might try it, to see whether my mystery word comes back to me...

Monday 21 February
Perhaps I've just been lucky, but only twice in all the years I have been travelling to the Channel Islands have I been inconvenienced by fog (actual, as opposed to mental, which is much more frequent).  Last Friday my journey was delayed by four hours as we sat in Guernsey Airport, enveloped by a thick blanket of the foggy stuff, until a brief clear window opened and we bundled onto the plane and made our escape.  The first time it happened, I was on my way in, diverted to Jersey, and had to complete my journey by ferry - what an adventure!  On both occasions I ended up making friends with fellow strandees (new word alert), so there is always a silver lining to the fog.

Wednesday 16 February
I've been waiting for ages for the latest John Le Carré novel to come to me on the library list.  I've not read any of his books before, but this one is about money laundering.  And I'm mystified: I'm only fifty pages in and I've already (literally) lost the plot.  He does those long conversations without speaker names, so if you blink for too long you lose track of who's talking.  I will press on, in the hope that the laundering will eventually appear, but at the moment it seems to be all about tennis.  Yes, tennis.

Friday 11 February
Are you as confused about the Bribery Act as I am?  I thought it was going to take effect on 1 April 2011 (always odd when they choose April Fool's Day for these things...) but apparently it cannot come into force until three months after the publication of governmental guidance - for which we are still waiting.  The government has issued a couple of woolly statements about guidance being on its way, but the lack of a definitive timeframe is only the latest of the many uncertainties and confusions generated by this Act.

Monday 7 February
Wifi is a strange and wonderful thing.  I was on holiday in Singapore last week (did you guess from the Merlion?), and thanks to this magical service I was able to keep half an eye on reality while sitting by the pool and enjoying the tropical heat (and not reading those novels).  I did manage to work out how to leave an out-of-office message this time, which is a giant leap for Susan-kind.  Talking of technology, I was surprised to find that super-whizzy Singapore still uses signatures for credit card purchases rather than chip and pin - I had many opportunities to study this, what with the constant shopping and eating, eating and shopping.

Thursday 27 January
It feels very strange to be going away on holiday when everyone else is just coming back to work, but I need the break.  Does anyone else find that it takes so much effort to get ready for a holiday - not least by working ahead to meet obligations during and just after the break - that it's almost more tiring than not going at all!  That said, I keep looking at the huge selection of novels I have stockpiled, and can't wait to be sitting by a warm pool, looking out at the Merlion (there's a hint about my destination...) and not reading a single one of them.

Monday 24 January
There I was last night, watching "Antiques Roadshow" and knitting (I know: the glamour), when I spotted someone I knew.  "That's one of my MLROs!" I shouted, pointing and waving in excitement.  My husband barely looked up from his paper: "You're obsessed.  You're always seeing money laundering, and now you're hallucinating MLROs".  Frankly, it's a worry, as he could be right.  So I checked with the MLRO in question, and it was him, so I am relieved to say that I am not going mad.  Yet.

Wednesday 19 January
I know I shouldn't take pleasure in someone else's misfortune, but there is a a real thrill for me to be in town on the day when sentence was passed in what the local press is calling "the first clear case of money laundering ever to be heard in Guernsey".  I have bought two copies of the newspaper: one to read again and again, and the other to keep pristine for my scrapbook.  OK, maybe I am enjoying it too much.

Monday 17 January
I do wonder whether I should get psychiatric treatment, or just be grateful that I find my job so exciting!  The IMF report on Guernsey - for which we have been waiting for-EVAH - was published on Friday at 3pm, and I was standing by my printer at 2.55, barely able to stop myself from hopping up and down.  It's a generally favourable report, reflecting the huge amount of preparatory and reparatory work done in Guernsey relating to the IMF visit, but I was selfishly pleased to see that a couple of my own reservations had made it into print.  Always gratifying to be right - and reassuring (we all have those nightmares where you are found out and everyone realises that you don't know anything at all about your work!).

Friday 14 January
I don't mean to be a grumpy old woman, but really!  I was in London yesterday, trying to get onto the Northern Line.  The first train came, and was too full for us to board.  So I commented to the chap next to me, "Never mind, we'll get on the next one."  He smiled and we had a little chat about it all.  The next train arrived, and my new friend elbowed me out of the way to get on board!  But we'd bonded, I thought - exchanged pleasantries and connected as human beings.  Thank goodness I'm in Guernsey next week, and can toddle to work through the Candie Gardens.

Tuesday 11 January
I've been mentioning him in my training for as long as I can remember, and finally Tom DeLay is on his way to prison for money laundering.  I'm feeling slightly smug about it, as I have always predicted a short prison term for him (and three years is short in the US).  I'm now hoping that they increase it on appeal - it's always fun when they do that.  And he's showing no remorse at all, the little devil.

Wednesday 5 January 2011
Happy new year to you all - here's hoping that every one of you has just the right amount of snow and water.  Don't you love it when forward-planning pays off?  Two years ago I recorded a documentary from the telly, and as I prepare for my next MLRO workshop in April, I find that I need just exactly that documentary to illustrate a training point.  I feel all warm and fuzzy and contented - and not a little smug.