Publications

As part of my on-going examination of the important issues and developments in money laundering and financial crime, I write articles, books and other discussion documents on a regular basis - and also now appear on the (very small) silver screen.

My current publications are listed below.  If you would like to see any of them, please email Susan.

And do return frequently to this page - I am always adding to the list.

Articles
Books
Films

Documents published by other organisations

Articles

I write a monthly article for leading trade paper Money Laundering Bulletin, where I look at the AML regimes operating in various jurisdictions and also offer practical advice to MLROs on how to make their lives easier (short of resigning, of course).

Books

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.)

In the first three chapters found in Part 1, read about how 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.

In the three chapters published in Part 2, 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.

In the three chapters published in Part 3, read about 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.

Future parts - each containing three chapters - will be published at regular intervals.

For more details, please see the Amazon Kindle page for Part 1 or Part 2, or Part 3, or email Susan.

Money Laundering - A Training Strategy

My first book Money Laundering - A Training Strategy was first published in April 2002.  Published by Informa, this is the only practical guide to choosing, designing and delivering effective anti-money laundering training.  The second edition was published in June 2005, fully updated to include the requirements of the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2003.

For more details, please see the publication brochure or email Susan.

Money Laundering Officer's Practical Handbook

My second book is the Money Laundering Officer's Practical Handbook, and the first edition was published in July 2006.  The Money Laundering Officer's Practical Handbook (or MLOPH) has as its strap-line "Don't tell me what I need to know, tell me what I need to do!", and the intention has been to create as practical a guide as possible.  Written since the publication of the new JMLSG Guidance Notes in January 2006, MLOPH takes into account the recent changes in emphasis of the UK's AML regime, including a risk-based approach to everything and increased senior management accountability.  MLOPH features lots of bullet points and checklists, and even has removable, photocopiable resources at the back.  If you are an experienced UK MLRO, you can use MLOPH to check that your AML regime is still compliant and effective; if you are a newly-appointed MLRO in the UK, MLOPH will give you step-by-step guidance on how to implement such a regime.

MLOPH 2006/2007 was published in September 2006, MLOPH 2009 in August 2008, MLOPH 2010 in October 2009 and MLOPH 2011 in October 2010.

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Films

In March 2010, Lessons Learned published online its suite of anti-money laundering training films.  Among them are "Punishments and Penalties" (about the ABN AMRO and Lloyds penalties) and "Blood in the Water" (about money laundering through trade finance).  Both of these feature Susan, sounding rather posh and fierce.

To view the films, click here.  You can subscribe to the whole suite of films - covering money laundering and other operational risk issues - for £1,000 a year, which gets you up to 3,000 hours' viewing.  If you do subscribe, please mention my name, as I did this as a favour to Lessons Learned and would like to know whether to do it again.

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Documents published by other organisations

Customer Due Diligence for Banks - published by the Basel Committee on Banking Supervision (October 2001)

Overriding Principles for a Revised Know Your Customer Framework - position paper published by Guernsey Financial Services Commission, Jersey Financial Services Commission and Isle of Man Financial Supervision Commission (February 2002)

The UK's Anti-Money Laundering Legislation and the Data Protection Act 1998: Guidance Notes for the Financial Sector - government guidance published by HM Treasury (April 2002)

Wolfsberg Anti-Money Laundering Principles for Private Banking - published by Wolfsberg Group of leading financial institutions (May 2002 edition)

Proceeds of Crime Act 2002 Part 7 (Money Laundering): Section 339 Form and Manner of Disclosures - consultation paper published by the UK Home Office (August 2002)

Combating the Abuse of Non-Profit Organisations: International Best Practices - published by the FATF (October 2002)

Money Laundering Sourcebook (Amendment) Instrument 2002 - statutory instrument published by UK Financial Services Authority (October 2002)

Towards a Level Playing Field - report on the regulation of corporate vehicles published by the International Tax and Investment Organisation and the Society of Trust and Estate Practitioners (October 2002)

Wolfsberg Anti-Money Laundering Principles for Correspondent Banking - published by Wolfsberg Group of leading financial institutions (November 2002)

Report on the Outcome of the FATF Plenary meeting and Proposal for the Endorsement of the Methodology for Assessing Compliance with the AML/CFT Standard - published by the Monetary and Exchange Affairs and Legal Departments of the IMF (November 2002)

Hawala: how does this system work, and should it be regulated? - published by the IMF's Monetary and Exchange Affairs Department (December 2002)

Money Laundering: A Banker's Guide to Avoiding Problems - published by the US Office of the Comptroller of the Currency (January 2003)

FIUs in Action: 100 Cases from the Egmont Group - published by the Egmont Group of FIUs (February 2003)

United Kingdom: Financial System Stability Assessment [including reports on the AML and CFT position] - published by the IMF (February 2003)

Joint Interim Progress Report of the Work of the IMF and the World Bank [with regard to anti-money laundering] - published by the IMF (March 2003)

Initiatives by the BCBS, IAIS and IOSCO to combat money laundering and the financing of terrorism - published by the Joint Forum (June 2003)

United Kingdom Threat Assessment of Serious and Organised Crime 2003 - published by NCIS (August 2003)

Consolidated KYC Risk Management - a consultative document published by the Basel Committee (August 2003)

Suppressing the Financing of Terrorism: A Handbook for Legislative Drafting - published by the Legal Department of the International Monetary Fund (August 2003)

TAXline: Money Laundering - a tax practice supplement published by the Tax Faculty of the Institute of Chartered Accountants in England and Wales (September 2003)

Money Laundering Regulations 2003 - statutory instrument published by HMSO (December 2003)

Harmful Tax Practices: The 2004 Progress Report - report published by the OECD (February 2004)

Cybercrime and the Proceeds of Crime Act - guidance paper published by the Fraud Advisory Panel (March 2004)

One Step Ahead: A 21st Century Strategy to Defeat Organised Crime - white paper published by the Home Office (March 2004)

Fraud Law Reform: Consultations on proposals for legislation - consultation paper published by the Home Office (May 2004)

Informal consultation on the Third EC Money Laundering Directive - consultation paper published by HM Treasury (May 2004)

Confronting the Threat: Serious and Organised Crime in Northern Ireland Threat Assessment & Strategy 2004 - report published by the Northern Ireland Organised Crime Task Force (May 2004)

Anti-Money Laundering Strategy - paper published by the UK government (October 2004)

FinCEN Strategic Plan 2006-2008 - paper published by the Financial Crimes Enforcement Network (February 2005)

Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism - published by the Council of Europe (May 2005)

Anti-Money Laundering Procedures Republic of Ireland - published by the Institute of Chartered Accountants in Ireland (September 2005)

UK Law Enforcement Agency Use and Management of Suspicious Activity Reports: Towards Determining the Value of the Regime - published by University College London (June 2005)

Third EU Directive on Money Laundering - published by the Council of Europe (November 2005)

Anti-money laundering guidance for solicitors undertaking property work - guidance published by the UK Law Society (December 2005)

Proceeds of Crime Act 2002 and Money Laundering Regulations 2003 (Amendment) Order 2006 - statutory instrument published by HMSO (February 2006)

Guidance for solicitors undertaking private client work - guidance published by the UK Law Society (February 2006)

United Kingdom Threat Assessment of Serious Organised Crime - published by SOCA (July 2006)

Report on the Misuse of Corporate Vehicles for money laundering - published by the FATF (November 2006)

Report on the abuse of New Payment Methods by money launderers - published by the FATF (November 2006)

Report on the Laundering of the Proceeds of VAT Carousel Fraud - published by the FATF (March 2007)

Principles-based regulation - focusing on the outcomes that matter - paper published by the UK's Financial Services Authority (April 2007)

Money Laundering Guidance: Company and Commercial - guidance published by the UK Law Society (April 2007)

Financial Services Authority Annual Report 2006/07 - published by the UK's financial regulator (June 2007)

Guidance on the Risk-Based Approach to Combating Money Laundering and Terrorist Financing: High Level Principles and Procedures - published by the FATF (June 2007)

Tax Co-operation: Towards a Level Playing Field - 2007 Assessment by the Global Forum on Taxation - report published by the OECD (October 2007)

Anti-Money Laundering Guidance for the Accountancy Sector - exposure draft issued by the UK Consultative Committee of Accountancy Bodies (October 2007)

Prevention of Money Laundering/Combating Terrorist Financing - UK guidance notes published by the Joint Money Laundering Steering Group (November2007)

Protecting Against Money Laundering - guidance issued for UK estate agents by the NAEA and RICS (November 2007)

The Suspicious Activity Reports Regime Annual Report 2007 - report published by the UK's Serious Organised Crime Agency (November 2007)

TECH 07/07: Anti-Money Laundering Guidance for the Accountancy Sector - guidance published by the Consultative Committee of Accountancy Bodies (December 2007)

Money Laundering Regulations 2007 - statutory instrument published by HMSO (15 December 2007)

Money Laundering (Amendment) Regulations 2007 - statutory instrument published by HMSO (15 December 2007)

The Prevention of Money Laundering and Combating the Financing of Terrorism: Guidance for remote and non-remote casinos - guidance published by the UK Gambling Commission (December 2007)

Anti-Money Laundering Practice Note - guidance issued by the Law Society of England and Wales (February 2008)

TECH 05/08: Anti-Money Laundering Guidance for the Accountancy Sector - guidance published by the Institute of Chartered Accountants in England and Wales (August 2008)

The Wolfsberg Trade Finance Principles - standard industry practice published by the Wolfsberg Group (January 2009)

International Narcotics Control Strategy Report 2009 - annual report published by the US Department of State (March 2009)

Financial services firms' approach to UK financial sanctions - report published by the Financial Services Authority (April 2009)

Combating Money Laundering and Recovering Looted Gains - report published by Transparency International UK (June 2009)

Financial Services Authority Annual Report 2008/09 - published by the FSA (June 2009)

Money Laundering through the Football Sector - published by the FATF (July 2009)

Guernsey Financial Services Commission Annual Report 2009 - published by the Guernsey regulator (July 2010)

Fighting Fraud Together - published by the UK Home Office (October 2011)

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For more information about Thinking about Crime Limited, click here to email Susan

Click on the book covers to read more about Susan's e-books - the serialised adventures of an MLRO

And to see Susan's latest musings on money laundering, click here to read her blog

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