On 28 January, the Centre for European Policy Studies published a paper which sets out the following key recommendations for a new approach to the fight against money laundering.  It says that banks and other ‘obliged entities’ complete thousands of SAR on a daily basis yet only a handful are followed up on by FIU.  This could be due to lack of capability, capacity or even political direction.  Meanwhile, the breadth and means to launder money have also increased, facilitated by technological progress.  Unfortunately, the current AML regulations have brought little success.  The paper includes a chart detailing the effectiveness ratings (“Immediate Outcomes” markings) for EU states.

If you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing costs of relocation, removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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