Oliver Bullough

This is a contributor index. It brings together the material carried on AML Network under the byline above and records the editorial standards that contributed work is written to. It contains no biographical claims.

Independence of contributed work

Contributors write independently of the publication's commercial arrangements and of any organisation that may be the subject of their work. No advertiser, sponsor or subscriber sees copy before publication or influences what is examined. Where a contributor has an interest in a matter — a past professional relationship, a paid engagement, a financial holding — the interest is disclosed in the piece, or the piece is not published.

Reporting, analysis and comment

The three are kept distinct. Reporting states what can be evidenced. Analysis draws inferences from that evidence and shows its reasoning. Comment argues a position. Debate about anti-money-laundering policy frequently blends all three — an argument that a regime is ineffective, for instance, depends on what one takes the regime to be for — and separating them allows a reader to accept the facts while rejecting the conclusion.

Jurisdiction and legal framing

Obligations described in one jurisdiction are not assumed to hold in another. Customer due diligence requirements, beneficial-ownership thresholds, definitions of a politically exposed person, tipping-off offences and the treatment of professional privilege all vary between regimes, and supervisory powers vary further still. Contributed work identifies the instrument and jurisdiction it is describing, and avoids presenting a national rule as an international standard unless it genuinely derives from one.

Accuracy and redress

Errors are corrected on the page, dated and described. Individuals and firms named in coverage may ask for a correction or clarification and may supply supporting material; requests are assessed on the evidence. Where a legal matter concludes differently from how it stood at an earlier stage, the piece is updated so that the earlier account does not remain as the site's record of the outcome.