Monthly Archives: September 2013

Cooking with gas

Posted on September 30, 2013 by Susan Grossey author

As I was reminded today when I checked my watch and realised that the numbers seems to have shrunk somewhat, time is passing. And although we are all now so familiar with the basic principles of the AML regime that … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, due diligence, financial crime, guidance, legislation, ML Regulations, training | 7 Comments

Too close for comfort

Posted on September 26, 2013 by Susan Grossey author

It’s a training week for me – one of my favourite ways to spend my time – and it is always particularly gratifying when something I am talking/warning about is featured in the news, preferably on the very day of … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged AML, due diligence, financial crime, money laundering, organised crime, people trafficking, proceeds of crime, slavery, suspicion, white collar crime | 4 Comments

The trouble with paranoia…

Posted on September 24, 2013 by Susan Grossey author

…is that sometimes they really are out to get you. I missed this case over the summer, but thankfully a friendly MLRO pointed it out to me. Back in 2006, German Gustl Mollath went to the authorities with claims that his … Continue reading →

Posted in AML, Money laundering, Organised crime, White collar crime | Tagged AML, corruption, due diligence, financial crime, money laundering, organised crime, proceeds of crime, white collar crime | Leave a comment

When good people go bad

Posted on September 20, 2013 by Susan Grossey author

About a year ago, I wrote a blog post on the importance of keeping an avuncular eye on your staff, so that you can spot if they fall (or start to trip) from the path of righteousness. I was reminded … Continue reading →

Posted in AML, Money laundering | Tagged AML, corruption, due diligence, financial crime, money laundering, proceeds of crime, tax evasion | 2 Comments

Even Casanova went bankrupt eventually

Posted on September 18, 2013 by Susan Grossey author

The other day I read an article on the BBC website that made me laugh out loud. Apparently the recent recession is having a particularly devastating effect on the wooing habits of Italian men, who can no longer afford to … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, asset forfeiture, bribery, corruption, due diligence, financial crime, money laundering, organised crime, proceeds of crime, tax evasion, white collar crime | Leave a comment

Strange bedfellows?

Posted on September 16, 2013 by Susan Grossey author

An MLRO of my acquaintance emailed me recently and asked whether I thought it would be OK for her – as her Board had requested – to incorporate her AML manual into a more general compliance manual. And this started … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, communication, corruption, due diligence, financial crime, ML Regulations, MLRO, money laundering, proceeds of crime, training, white collar crime | 3 Comments

Watching out for money launderers

Posted on September 12, 2013 by Susan Grossey author

In a recent TV documentary about fraudsters and their laundering techniques, a fraud squad detective is seen beaming with joy as he searches a suspect’s bedroom and finds a box containing a brand-new gold Rolex watch, complete with a receipt … Continue reading →

Posted in Money laundering, Organised crime | Tagged AML, asset forfeiture, due diligence, financial crime, money laundering, organised crime, PEP, proceeds of crime, tax evasion, white collar crime | 3 Comments

It’s nothing without the name

Posted on September 10, 2013 by Susan Grossey author

I recently met someone who had been to a training session I gave years ago, and he said that the one thing that had stuck in his mind was the concept of smurfing. (For those of you scratching your heads, … Continue reading →

Posted in Money laundering, Organised crime | Tagged corruption, financial crime, money laundering, organised crime, proceeds of crime, smurfing, white collar crime | 4 Comments

How do you talk to someone about their BO?

Posted on September 6, 2013 by Susan Grossey author

No, not that particular problem: thanks to the proliferation of manly deodorants called things like Overlord or Hunkmeister, plus aircon, the problem of the whiffy colleague has generally gone. I’m talking about that other unmentionable: beneficial ownership. With the revision … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, beneficial ownership, communication, disclosure, due diligence, equivalence, financial crime, money laundering, organised crime, PEP, proceeds of crime, white collar crime | Leave a comment

Local laundering

Posted on September 4, 2013 by Susan Grossey author

As you read this, I am enjoying the sunshine (well, the aircon while looking out at the sunshine) of Gibraltar. I am delivering two days of training to members of the Gibraltar Association of Compliance Officers, and – as always … Continue reading →