Monthly Archives: November 2015

Dire warnings

Posted on November 26, 2015 by Susan Grossey author

They say that if you can’t be a good example, then aim to be a dire warning instead. And this is always the spirit in which I have read reports of “findings” – the more palatable term for regulatory punishments. … Continue reading →

Posted in AML, Training | Tagged AML, due diligence, FCA, Financial Conduct Authority, regulator, training | Leave a comment

Double-duty SARs

Posted on November 23, 2015 by Susan Grossey author

Ever since some hunter in ancient times pulled back his slingshot and managed to kill two birds with one stone, we humans have loved achieving two (and if possible more) ends with one action. For instance, it is helpful to … Continue reading →

Posted in AML, Money laundering, Uncategorized | Tagged AML, disclosure, due diligence, financial crime, money laundering, proceeds of crime, SARs, suspicion | Leave a comment

Back to laundering basics

Posted on November 20, 2015 by Susan Grossey author

Just to give you a breather after that last post, which taxed your brain cells, this time I am looking at the other end of the spectrum. I was watching “Look East” a few days ago, which is our local … Continue reading →

Posted in Money laundering | Tagged asset forfeiture, financial crime, money laundering, National Crime Agency, proceeds of crime, Proceeds of Crime Act | 5 Comments

Taxing tax evasion

Posted on November 17, 2015 by Susan Grossey author

In this post we are getting right down to what a French friend of mine once called “the nitties and the gritties”, so thinking caps on, please. An MLRO has written to me with a vexing conundrum around consent concerning … Continue reading →

Posted in AML, Money laundering | Tagged consent, due diligence, financial crime, legislation, MLRO, proceeds of crime, Proceeds of Crime Act, suspicion, tax evasion | 10 Comments

Confession is good for the soul

Posted on November 12, 2015 by Susan Grossey author

The lovely film “Out of Africa” contains one of my favourite cinematic lines of all time. No, it’s not a declaration of love from mahogany Rob to multi-accented Meryl, but rather the response from her dastardly soon-to-be-ex-husband, the splendidly-named Baron … Continue reading →

Posted in AML, Money laundering, Publications | Tagged AML, Cayman Islands, FATF, Financial Action Task Force, legislation, money laundering, National Risk Assessment | 1 Comment

And they lived PEPily ever after

Posted on November 9, 2015 by Susan Grossey author

The Fourth Money Laundering Directive is the gift that just keeps on giving, isn’t it? It’s a meaty document, and one of the delights it has served up – following the recommendation of the FATF’s, well, Recommendations – is an … Continue reading →

Posted in AML, Money laundering | Tagged AML, corruption, due diligence, Guernsey, Isle of Man, Jersey, ML Regulations, PEP, proceeds of crime, suspicion | 3 Comments

Running scared

Posted on November 6, 2015 by Susan Grossey author

Over lunch yesterday, a friend of mine told me a story so bizarre that I have to share it with you. But for reasons that will become obvious, I have to keep it all anonymous. My friend’s sister lives in … Continue reading →

Posted in Money laundering | Tagged financial crime, money laundering, organised crime, proceeds of crime, SARs, suspicion | 7 Comments

The realms of cash

Posted on November 3, 2015 by Susan Grossey author

Money laundering has changed almost beyond recognition since the days of “Scarface”, when Al Pacino’s drug kingpin Tony Montana washed his millions of dollars of drug proceeds by delivering mailbags of cash to his banker friend Jerry. Indeed, those of … Continue reading →