Insights

5 min read

Writing the policy is the easy part

A compliance program is judged on what you can show you did — not on what the document says you would do. That difference decides what you need to keep.

4 min read

The AML/CTF acronym cheatsheet

Every acronym you will meet running an AML/CTF program, in plain English, on one page. Built to be printed and kept next to the desk.

CC-101 · Lesson 1

5 min read

Why property attracts dirty money

Nobody in real estate signed up to fight financial crime. Understanding why property is attractive to it makes the rest of this a great deal easier to carry.

CC-101 · Lesson 1

5 min read

You are a reporting entity. So what changes?

"Reporting entity" sounds like paperwork. It is really a description of who carries the obligation — and it does not move, no matter who you hire to help.

CC-101 · Lesson 2

4 min read

Your job title has nothing to do with it

The most common question in an agency is "does this apply to me?" It is the wrong question, and the right one is easier to answer.

CC-101 · Lesson 2

4 min read

The people who get missed

Most programs cover the sales team well. The gaps are almost always somewhere quieter — and that is where a first impression of a customer gets formed.

CC-101 · Lesson 3

5 min read

What an AML/CTF program is actually made of

People talk about "the AML/CTF program" as though it is a document. It is six moving parts, and knowing which is which makes the whole thing far less daunting.

CC-101 · Lesson 3

4 min read

A copied risk assessment describes someone else’s business

It is the most skipped-over part of the program and the one everything else rests on. A borrowed one does not just fail on its own — it makes every decision above it unsupportable.

CC-101 · Lesson 4

5 min read

Seven families of red flag in property

Nobody remembers a list of forty indicators. Almost everybody can remember seven shapes — and the shapes are what you are actually looking for.

CC-101 · Lesson 4

4 min read

One flag is a question. Three is a pattern.

The hard part is not spotting something odd. It is what you do in the twenty minutes afterwards, when the innocent explanation starts to sound reasonable.

CC-101 · Lesson 5

4 min read

The one rule where "I was only being helpful" is no defence

Almost nobody tips off deliberately. It happens because a good agent wants to keep a client informed — which is exactly why it needs to be a reflex rather than a judgement call.

CC-101 · Lesson 5

3 min read

What to say when a customer asks why it is taking so long

Improvising an answer to a fair question is where good people get into difficulty. The fix is to stop improvising.

CC-101 · Lesson 6

4 min read

Notice and escalate. Do not decide.

The single most useful instruction in AML/CTF training is also the one that takes the most weight off the person receiving it.

CC-101 · Lesson 6

4 min read

What your compliance officer actually needs from you

Escalating is easy. Escalating usefully takes a small amount of discipline, and it is the difference between a decision someone can make and one they cannot.