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SUSPICIOUS ACTIVITY: The Adventures of an MLRO
Edward Jones is a Money Laundering Reporting Officer at Radleys Bank. In common with other MLROs, he has to balance legal
requirements, recalcitrant colleagues and sniffy customers. He first appeared in the pages of Money Laundering Bulletin, and is
now being published as a serialised e-book on the Kindle platform. (Free software from Amazon can be downloaded to enable
iPads, iPods, Windows PCs and Macs to download and read Kindle e-books.)
Part 1: Chapters 1-3
Our intrepid hero survives the
(thankfully temporary) suspension of
the Money Laundering Regulations,
the discovery that one of his account
managers has disappeared with a lot
of money, and the realisation that he
needs to train all of his staff - including
his nemesis, Director of New Business
Giles Ferguson.
To buy Part 1, click here:
Part 2: Chapters 4-6
Edward gets to grips with the joy that
is staff AML training while coping with
cheating colleagues and failing
lawyers. His life improves slightly
when a keen new compliance officer
joins the team - but then points out
that the corporate AML manual is a
disaster. And then the long
unlamented Jack Greenway comes
back into view as Edward and his
team receive a top-quality SAR - from,
of all places, the new business
department.
To buy Part 2, click here:
Part 3: Chapters 7-9
The gradual unravelling of the
relationship of Radleys Bank with the
Marmalade Mining Company in Peru.
Edward grapples with the aftermath of
refused consent from SOCA, and
discovers just how inadequate his
record-keeping procedures have been.
And just as he manages to get all of
that under control, the Bribery Act
2010 rears its ugly head. Being the
MLRO of a private bank in London is
definitely not for the faint-hearted.
To buy Part 3, click here:
Part 4: Chapters 10-12
Edward wrestles with upgrading the
staff vetting procedures in his bank,
much to the horror of Jenny in HR. He
then deals with his own geographical
inadequacies that are highlighted by
the acceleration in sanctions. And just
as he pauses to catch his breath,
Director of New Business Giles
Ferguson comes to him with a family
problem that soon turns into a money
laundering concern...
To buy Part 4, click here:
Part 5: Chapters 13-15
Edward starts to untangle the web of
connections between staff at his bank,
their families and close associates -
and a corrupt PEP. Realising that the
FSA is now focussing on high risk
money laundering situations, and the
treatment by banks of high risk
customers and particularly PEPs,
Edward and his compliance
colleagues tackle their approach to
enhanced due diligence. And a
childhood friend of Edward's
resurfaces to give him some much-
needed support and encouragement.
To buy Part 5, click here:
Part 6: Chapters 16-18
In the final three chapters published in
Part 6, Edward faces an Arrow visit
from the FSA, looks ahead to the
changes proposed by the FATF and a
new European Money Laundering
Directive, and thinks about his own
future - how can he contribute even
more to the world of AML?
To buy Part 6, click here:
ANTI-MONEY LAUNDERING
TRAINING AND ADVICE