Andy Greenberg

This page collects the work published on AML Network under the byline above. It is a contributor index and a statement of the standards that apply to contributed work; it does not describe the contributor's career, affiliations or opinions.

How contributed work is commissioned

Contributions are commissioned on a subject, not on a conclusion. A commission sets out the question to be examined and the material expected to bear on it; it does not specify what the piece should find. Where a line of enquiry does not stand up, that is a legitimate outcome, and the piece is not published as though it had.

Documents, data and verification

Much anti-money-laundering reporting rests on documents: corporate registries, court files, sanctions listings, regulatory notices, procurement records and obtained datasets. The standards applied to them are ordinary ones — establish provenance, corroborate against an independent record where possible, and describe what a document actually shows rather than what it is assumed to imply. A company appearing in a chain of ownership is not thereby a wrongdoer; a name matching a sanctions entry is not thereby the listed person; a report of suspicious activity is a report of suspicion, not a finding of fact.

Fairness to named parties

• Anyone facing significant criticism is given a fair opportunity to respond before publication, with enough detail to answer.
• Denials and explanations are carried in the body of the piece, not appended out of sight.
• Where a person or firm is named only as an intermediary, a counterparty or a former officer, the limits of their involvement are stated explicitly.
• Identifying details of sources, complainants and uncharged individuals are withheld where publication would cause harm disproportionate to the public interest.

Corrections

Factual errors are corrected on the page with a note recording the change and its date. Where the underlying position changes after publication — an appeal succeeds, an investigation closes, a regulator withdraws a notice — the piece is updated rather than left to stand on superseded facts.