Monthly Archives: July 2015

They’re not going on a summer holiday

Posted on July 28, 2015 by Susan Grossey author

As you pack your bucket and spade, I thought you might like to spare a thought for those poor people not having a summer holiday this year. I mean, of course, those put-upon convicted UK drug traffickers who have been … Continue reading →

Posted in Legislation, Organised crime | Tagged asset forfeiture, financial crime, legislation, National Crime Agency, organised crime, proceeds of crime | 4 Comments

Begone, bad MLRO

Posted on July 21, 2015 by Susan Grossey author

In what the headline writers are calling a “landmark case”, an MLRO and the firm she worked for in Jersey have been acquitted of failing to make suspicious activity reports when they should have done. (“Landmark” because it was the … Continue reading →

Posted in AML, Money laundering | Tagged due diligence, Jersey, Jersey Financial Services Commission, JFSC, legislation, MLRO, money laundering, suspicion | 4 Comments

A regime of responsibilities

Posted on July 17, 2015 by Susan Grossey author

On 7 July, the Financial Conduct Authority issued its final rules on the Senior Managers Regime (I long to put an apostrophe in there, but the regulator has decreed it apostrophe-free, and I’m nothing if not obedient to regulatory decree) … Continue reading →

Posted in Due diligence, Legislation | Tagged due diligence, FCA, Financial Conduct Authority, financial crime, government, legislation, MLRO, non-executive directors | Leave a comment

Agents of doom and disrepute

Posted on July 14, 2015 by Susan Grossey author

I’ve just watched a Channel 4 documentary called “From Russia with Cash”. The premise is that two investigators go undercover as Russian PEP Boris and his ditsy girlfriend Nastya, and trip around the swankier parts of London looking at five … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, corruption, due diligence, estate agent, financial crime, legislation, ML Regulations, money laundering, Money Laundering Regulations, PEP, proceeds of crime, Proceeds of Crime Act | 6 Comments

DD dire warnings

Posted on July 10, 2015 by Susan Grossey author

A while ago, I mulled on the meaning on the phrase “due diligence”. My mullings came back to bite me this week as I leafed through the Spectator magazine and spotted Dot Wordsworth’s column. Dot writes about the sources, meanings … Continue reading →

Posted in AML, Due diligence | Tagged AML, due diligence, money laundering | 3 Comments

Guernsey goes through the reputational wringer

Posted on July 7, 2015 by Susan Grossey author

I must declare an interest. As part of my regular timetable of training visits, I go to Guernsey about five times a year, for a week at a time. And I like it very much: I like the scenery, I … Continue reading →

Posted in AML, Legislation | Tagged AML, due diligence, financial crime, Guernsey, tax evasion | Leave a comment

High risk movers and shakers

Posted on July 6, 2015 by Susan Grossey author

The regular updating by the Financial Action Task Force of their list of dodgy places (or, more tactfully, high-risk and non-cooperative jurisdictions) is now part of every MLRO’s diary. Although I am the first to admit that inclusion on – … Continue reading →

Posted in AML, Money laundering | Tagged AML, communication, due diligence, FATF, Financial Action Task Force, financial crime, MLRO, money laundering, research | Leave a comment

Cash concerns

Posted on July 2, 2015 by Susan Grossey author

Earlier this week, I talked about the National Crime Agency’s “National Strategic Assessment of Serious and Organised Crime 2015” – and in particular about its take on high-end money laundering and professional enablers. But in case you’re feeling all complacent … Continue reading →