Monthly Archives: November 2013

… And known close associates

Posted on November 29, 2013 by Susan Grossey author

I think we can all agree that 2013 has been something of an anno expectatio for the Vatican. In May 2013 their FIU (the Autorità di Informazione Finanziaria, or AIF) published its first annual report – rather short on detail but long … Continue reading →

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

Listing to starboard

Posted on November 27, 2013 by Susan Grossey author

As every MLRO can recite in his sleep, there are four elements to money laundering risk analysis: customer risk, product risk, delivery channel risk, and jurisdiction risk. Only by looking at all four of these can you come up with … Continue reading →

Posted in AML, Money laundering | Tagged AML, communication, corruption, due diligence, equivalence, FATF, Financial Action Task Force, money laundering, PEP, proceeds of crime | 3 Comments

On your marks, get set, MLRO!

Posted on November 25, 2013 by Susan Grossey author

I remember my first day at university very well, even though it was so long ago that the whole experience was in black and white. As I was leaving my college to walk into town for the first time, the … Continue reading →

Posted in AML, Money laundering | Tagged AML, communication, due diligence, FATF, financial crime, legislation, MLRO, money laundering, Money Laundering Reporting Officer, organised crime, suspicion, training, white collar crime | 7 Comments

The clue is in the name

Posted on November 21, 2013 by Susan Grossey author

Singers sing, dancers dance, plumbers plumb – and directors direct. But you cannot direct unless you know where you are going and (in overall terms) how to get there. And I think too many directors have forgotten that their primary … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, directors, disclosure, due diligence, financial crime, Guernsey, legislation, non-executive directors, proceeds of crime, suspicion, training, white collar crime | 6 Comments

HMRC fines HGV HVD for AML failings

Posted on November 19, 2013 by Susan Grossey author

In its first AML prosecution of a high value dealer, the UK’s HMRC has fined Bedfordshire company director Grenville Eames £16,000 for failing to abide by the Money Laundering Regulations 2007. Eames’ company, JGE Commercials Limited, was also fined £16,000 and … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, director, due diligence, financial crime, High Value Dealer, HMRC, ML Regulations, money laundering | 6 Comments

Leaving the AML club

Posted on November 15, 2013 by Susan Grossey author

A little while ago, Guernsey followed the lead of various other countries and removed general insurance from its AML regime. As explained on the FAQ page of the Guernsey Financial Services Commission’s website: “Intelligence and information in the jurisdiction identified … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, due diligence, financial crime, insurance, ML Regulations, money laundering, suspicion, tax evasion | 9 Comments

Just who will the aid money aid?

Posted on November 13, 2013 by Susan Grossey author

With the headlines full of Typhoon Haiyan, people’s minds turn inevitably – and rightly – to aid donations. But when a country like the Philippines is involved, AML people’s minds turn inevitably to questions about corruption: bluntly, is it safe … Continue reading →

Posted in Bribery and corruption, Money laundering, Organised crime | Tagged AML, asset forfeiture, bribery, corruption, equivalence, financial crime, government, money laundering, organised crime, PEP, proceeds of crime, white collar crime | 4 Comments

First do no laundering

Posted on November 11, 2013 by Susan Grossey author

Stuck in traffic on the M11 yesterday afternoon, my husband and I – having divided up the last of the emergency wine gums – embarked on a philosophical discussion prompted in part by my blog post last week about Kier … Continue reading →

Posted in AML, Money laundering | Tagged AML, corruption, financial crime, MLRO, money laundering, proceeds of crime, suspicion, tax evasion, white collar crime | 2 Comments

It’s payback time for Cocky

Posted on November 7, 2013 by Susan Grossey author

I’m not normally a vindictive person, but when it comes to money launderers, my bile knows no bounds. I’m not quite calling for the death penalty, but I’m a bit sad that the birch has gone, and many long years … Continue reading →

Posted in AML, Money laundering | Tagged AML, asset forfeiture, disclosure, financial crime, Jersey, money laundering, organised crime, proceeds of crime, white collar crime | 3 Comments

Where AML leads, Kier Starmer follows

Posted on November 4, 2013 by Susan Grossey author

The fabulously-named Kier Starmer (the UK’s former Director of Public Prosecutions) is all over the news today, calling for a mandatory reporting law around child abuse, with those who fail to report facing prison sentences (as is already the case … Continue reading →