Monthly Archives: October 2012

A shiny coat and a wet nose

Posted on October 31, 2012 by Susan Grossey author

I’ve been wondering about this for a while: what makes a good MLRO? No doubt you have guessed by now that MLROs are among my Very Favourite People (up there with policemen working as financial investigators, Lucy Worsley, Jeremy Paxman, … Continue reading →

Posted in Due diligence, Money laundering | Tagged communication, due diligence, financial crime, legislation, ML Regulations, MLRO, money laundering, Money Laundering Reporting Officer, research, training, writing | Leave a comment

You are the weakest link

Posted on October 29, 2012 by Susan Grossey author

You’ve heard of early adopters – people who are at the vanguard of everything, queuing overnight to see the latest movie or buy the newest book, constantly upgrading their technology? Well, that’s not me: I’m a laggard. I still have … Continue reading →

Posted in Due diligence, Money laundering | Tagged AML, communication, due diligence, financial crime, money laundering, PEP, research, training | Leave a comment

Anything to declare?

Posted on October 26, 2012 by Susan Grossey author

One of my AML-related news searches threw up (I may regret using that term) an interesting story recently: two men were arrested at Medellin airport in Colombia for attempting to smuggle US$80,000 in cash – which they had swallowed rolled … Continue reading →

Posted in Money laundering, Organised crime | Tagged asset forfeiture, corruption, disclosure, financial crime, fraud, money laundering, organised crime, proceeds of crime, smuggling, tax evasion, white collar crime | 2 Comments

Tender is the process

Posted on October 24, 2012 by Susan Grossey author

As a one-person business (and proud of it – except when it comes to a rather lonely Christmas party), I rarely get involved in tendering (tenderising?). Usually someone contacts me, says “Can you do our training?”, and I say “Oh, … Continue reading →

Posted in Due diligence, Money laundering | Tagged AML, communication, disclosure, due diligence, financial crime, FSA, money laundering, proceeds of crime | Leave a comment

It does what it says on the form

Posted on October 22, 2012 by Susan Grossey author

Clunk click every trip. Don’t die of ignorance. Don’t be an amber gambler. It depends on your age, but everyone can remember some public information slogans from their childhood and youth (and beyond – that middle one was for AIDS … Continue reading →

Posted in Due diligence, Money laundering | Tagged AML, communication, due diligence, financial crime, money laundering, research, training, writing | 3 Comments

Cleaning up our own house

Posted on October 19, 2012 by Susan Grossey author

Mid-February this year was jolly exciting: it was my birthday, and the FATF published the revised version of their Forty Recommendations. (Only one of these was marked by a family-sized Battenberg cake with a candle stuck in it – I’ll … Continue reading →

Posted in Due diligence, Money laundering | Tagged AML, corruption, due diligence, FATF, Financial Action Task Force, financial crime, legislation, money laundering, organised crime, PEP, proceeds of crime, tax evasion | Leave a comment

Oiling the wheels

Posted on October 17, 2012 by Susan Grossey author

Hah – I bet you thought this post was going to be about metaphorical oiling, i.e. bribery. But it’s not: it’s about literal oiling, i.e. the oil industry. A while ago I read a very thought-provoking book called “Crude World: … Continue reading →

Posted in Due diligence, Money laundering | Tagged AML, due diligence, equivalence, financial crime, ML Regulations, money laundering, proceeds of crime, research, tax evasion | 2 Comments

Missing presumed safe

Posted on October 15, 2012 by Susan Grossey author

A while ago, I wrote a blog post wondering why bookmakers are excluded from the UK’s AML/CFT regime. Of course, bookies are not the only holes in the system. Two others that spring to mind are high value dealers in … Continue reading →

Posted in Due diligence, Money laundering | Tagged AML, due diligence, equivalence, financial crime, legislation, ML Regulations, money laundering, organised crime, proceeds of crime | 2 Comments

The pig in shades hits a century

Posted on October 12, 2012 by Susan Grossey author

I think they call it a slow-burner – “Fifty Shades” it ain’t. But the pig in shades (more properly known as “Anti-Money Laundering: A Guide for the Non-Executive Director”) is gently warming his crackling, and since the publication of his … Continue reading →

Posted in Money laundering, Publications | Tagged communication, ML Regulations, money laundering, non-executive directors, proceeds of crime, publications, research | Leave a comment

Fractions ain’t what they used to be

Posted on October 11, 2012 by Susan Grossey author

En route to some training in London this week, I travelled up an escalator in Chancery Lane tube station. All the ads alongside were for jewellers in nearby Hatton Garden (note to self: diamonds are BIIIIIG these days) and for … Continue reading →