Thinking from
inside the work.

Enhanced due diligence under JMLSG Part I is triggered by specific factors identified at onboarding or during ongoing monitoring. Triggers fall into customer, jurisdictional, product and channel, and behavioural categories. A defensible framework documents which triggers apply and what evidence the firm obtained.

The Football Governance Act 2025 created the Independent Football Regulator with statutory powers no football club has previously had to answer to. The IFR can require licensing, examine ownership, demand financial information, and act on what it finds. Most clubs are operationally unprepared.

An FCA Skilled Person review under section 166 examines a firm's systems, controls, and decisions against a defined scope. The reviewer tests whether actual practice matches stated practice, whether decisions were supported by evidence at the time, and whether governance was real or theatrical.

DIFC and ADGM are both common law UAE financial centres aligned with FATF, but their CDD regimes are not interchangeable. The DFSA and FSRA diverge on documentation standards, beneficial ownership approach, screening expectations, and group reliance. Firms operating across both need methodology that respects the differences.

Source of wealth corroboration is the work that turns a client's stated wealth narrative into evidence the firm can defend. The FCA expects more than a self-declaration: a proportionate, risk-sensitive evidential chain that links wealth to its origin in a way an external reviewer can follow.

Under MLR 2017, a CDD risk rating must reflect a genuine, evidenced assessment of the client's money laundering risk, not a default position taken to satisfy a workflow. The rating needs three things to hold up: a documented methodology, the specific factors that drove the score, and a record of who reviewed it and when.

Past Business Reviews and s166 exercises are among the most operationally complex things a firm or a consultancy can be asked to run. The failure points are structural, and they appear at the same stages in almost every programme. Understanding them before the review starts is the only way to avoid them.

The Football Governance Act 2025 created something English football has never had: a statutory regulator with real powers, real enforcement, and a real obligation to licence every club in the top five tiers. Most clubs, agents, and advisors are not prepared for what the Independent Football Regulator will actually ask of them.

DIFC and ADGM have undergone a genuine regulatory shift since the UAE came off the FATF grey list in February 2024. The question is whether firms are building compliance or retrofitting it. The two are not the same thing, and the gap between them is what regulators find when they look closely.

The problem isn't that firms ignore the rules. It's that the infrastructure underneath the decision-making was never built to produce something defensible. There is a difference between a file that satisfies an audit and one that holds up under real scrutiny.

A practitioner's glossary of the terms that come up most often in UK and GCC regulated environments. Plain-English definitions covering CDD, EDD, MLR 2017, JMLSG Part I, FATF, the IFR regime, and the language of Skilled Person reviews.