Articles
Notes from inside the compliance function
Working notes from nine years of building and running AML systems inside banks — written for the people who do the job, not for a press release.
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AML Requirements for UK Asset Managers
Asset managers, AIFMs and wealth managers authorised by the FCA are in scope of the Money Laundering Regulations 2017 today. What that actually requires.
FinCEN Investment Adviser AML Rule: Now 2028
FinCEN has delayed AML and SAR requirements for RIAs and ERAs to 1 January 2028 and intends to re-tailor the rule. What changes, and what does not.
AMLFinCENInvestment AdvisersAsset ManagementRegulatory Change
Beneficial Owners in Fund and Trust Structures
Ownership stops resolving before it reaches a person. UK and EU thresholds, what a trust needs instead of a share register, and when the chain runs out.
Investor Due Diligence for Fund Managers
A subscription document is not customer due diligence. What a fund manager must establish when the investor is a company, a trust, a nominee or a feeder.
AMLInvestor OnboardingCustomer Due DiligenceAsset ManagementKYB
Source of Wealth vs Source of Funds
They are not the same check, and treating them as interchangeable is a common review finding. What each one establishes, and what counts as evidence.
AMLSource of WealthSource of FundsEnhanced Due DiligenceCustomer Due Diligence
Edge AI was half the answer
AI inside the bank settles the half of a case the bank already holds. The counterparty you know nothing about is on the public record — and that half needs a different architecture.
Is Your Job at Risk? — AI in Financial Crime Operations (Part 2)
AI is reshaping financial crime operations — but not the way most people think. We break down Executive AI vs Institutional AI, explain why agentic…
Same AI. Same Transaction. Two Opposite Verdicts.
Short and sharp Same AI. Same transaction. Different prompt. Opposite conclusions. The real risk of AI in financial crime prevention is not that it…
I Was Nearly Scammed — And We Build Financial Crime Prevention Systems for Banks
I am the founder of a company that builds real-time AML transaction monitoring for banks. I have spent nearly a decade in this industry. And I was…
Network Analysis in AML: Why You Don't Need a Graph Database
Traditional AML systems analyze transactions one at a time. Financial criminals work in networks. Here's how network analysis closes that gap — without…
Network AnalysisAMLTransaction MonitoringFraud DetectionFinancial Crime
Batch vs. Real-Time Monitoring in AML: Why Modern Systems Need Both
The AML industry frames batch and real-time monitoring as competing approaches. The truth is simpler: a modern system must support both — plus manual…
AMLAnti-Money LaunderingTransaction MonitoringBatch ProcessingReal-Time Monitoring
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