Monthly Archives: February 2015

Territorial sensibilities

Posted on February 26, 2015 by Susan Grossey author

I work regularly in five jurisdictions: the UK, Guernsey, Jersey, the Isle of Man and Gibraltar.  Now let’s get technical.  The Bailiwick of Guernsey (actually five islands) and the Bailiwick of Jersey are jointly the Channel Islands.  The Channel Islands … Continue reading →

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Out and proud: I’m AML and pro-tax

Posted on February 23, 2015 by Susan Grossey author

For years, tax has been AML’s dirty little secret.  Many’s the time an MLRO has taken me to one side just before a training session and asked, “Could you just mention, you know, just in passing, *whisper* tax to them – … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , | 7 Comments

SARs as information-sharing triggers?

Posted on February 18, 2015 by Susan Grossey author

Earlier this week, the head of the National Crime Agency, Keith Bristow, announced that his agency had entered into an information-sharing agreement with the ten largest British banks.  I have tried without success to find an official press release on … Continue reading →

Posted in AML, Legislation | Tagged , , , , , , , , , | 12 Comments

England’s new civil war

Posted on February 16, 2015 by Susan Grossey author

For rather obvious reasons, there has been a lot of hand-wringing in the media recently over what to do with tax evaders.  (I have my own rather Cromwellian ideas, but I shall keep them to myself.)  There seem to be … Continue reading →

Posted in AML, Money laundering | Tagged , , , , , , , , , | 12 Comments

Living high on the hog

Posted on February 14, 2015 by Susan Grossey author

I don’t usually post anything at the weekend, but this is just too exciting to wait – and anyway, it might all have changed by Monday.  Today my laptop went into something of a meltdown with its bookmarks, so I … Continue reading →

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Checking your seatbelt

Posted on February 12, 2015 by Susan Grossey author

It would be remiss of me to let “the HSBC situation” go by without comment.  I may well return to it in future, as I know some of the people involved and will try to get some MLRO-relevant details from … Continue reading →

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Back Row Boys

Posted on February 9, 2015 by Susan Grossey author

Last week I did lots and lots of training sessions in Guernsey, and it gave me an opportunity to consider an issue that I have noticed again and again.  Why, when presented with a room of empty seats, do people … Continue reading →

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The shadow of Shah

Posted on February 5, 2015 by Susan Grossey author

One of the aspects of my work that I love – and there are plenty – is that the goal-posts are always moving.  Criminals change what they do, launderers change how they work, and jurisdictions change their laws.  (I tried … Continue reading →

Posted in Legislation, Money laundering | Tagged , , , , , , , , , | 3 Comments

One for all and all for one

Posted on February 2, 2015 by Susan Grossey author

The concept of “joint enterprise” has been in the news again recently, this time because in December 2014 the Justice Committee (which examines the expenditure, administration and policy of the UK’s Ministry of Justice and its associated public bodies) announced that, … Continue reading →

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