Category Archives: AML

Ethics girls and boys

Posted on September 30, 2020 by Susan Grossey author

With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind. I come from mixed stock: one half of … Continue reading →

Posted in AML, Uncategorized, White collar crime | Tagged AML, communication, due diligence, ethics, financial crime, fraud, money laundering, research, risk-based approach, suspicion, training | 4 Comments

Latest leak lessons

Posted on September 23, 2020 by Susan Grossey author

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”. I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading →

Posted in AML, Money laundering, White collar crime | Tagged AML, communication, corruption, due diligence, Economist, financial crime, government, legislation, MLRO, money laundering, organised crime, Panorama, PEP, proceeds of crime, research, SARs, suspicion, suspicious activity report, white collar crime | 4 Comments

Sixth sense

Posted on September 16, 2020 by Susan Grossey author

Right, here’s a little quiz for you: as of today, it’s 78 days until what? Points deducted if you simply say, “Thursday 3 December” – although points added if you know that that’s my mother-in-law’s birthday [note to self: remind … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, Fifth Money Laundering Directive, financial crime, government, legislation, MLD5, MLD6, money laundering, organised crime, proceeds of crime, Sixth Money Laundering Directive, tax evasion | 6 Comments

AML for the autodidact

Posted on September 9, 2020 by Susan Grossey author

I’m a big fan of surveys and reports: give me a sniff of a group of compliance types being asked for their take on AML, and I’m there with my hand in the air, begging for the results, like the … Continue reading →

Posted in AML, Training | Tagged AML, communication, due diligence, financial crime, LexisNexis, money laundering, publications, research, training | 5 Comments

Is that why it’s called a PEP rally?

Posted on August 26, 2020 by Susan Grossey author

I am of An Age where every working surface in our house has been equipped with a cheap pair of reading glasses – who knows when I will need to read that care label, cooking instruction or baffling piece of … Continue reading →

Posted in AML, Due diligence, Legislation, Money laundering | Tagged AML, Bank Secrecy Act, due diligence, FATF, financial crime, government, legislation, money laundering, organised crime, PEP, Politically Exposed Person, proceeds of crime, tax evasion, white collar crime | 4 Comments

Happy holidays!

Posted on August 19, 2020 by Susan Grossey author

Well hello everyone – I’m back. And while I was away on my hols, I did wonder whether taking time off in the summer was the responsible thing to do. As long ago as 1831, astronomer and statistician Adolphe Quetelet … Continue reading →

Posted in AML, Fraud, Money laundering, Organised crime | Tagged AML, due diligence, financial crime, fraud, money laundering, organised crime, risk-based approach, white collar crime | Leave a comment

A word to the wise

Posted on July 22, 2020 by Susan Grossey author

MLROs and compliance folk are creatures of precision. I (proudly) count myself among them, and I know that when I am designing procedures or assembling training materials or writing this blog, I make sure that I check my sources very … Continue reading →

Posted in AML, Legislation, Regulation | Tagged AML, CDD, communication, due diligence, government, Jersey, legislation, MLCO, MLRO, money laundering, publications, writing | Leave a comment

Friends in low places

Posted on July 15, 2020 by Susan Grossey author

For my sins, I start every working day with a trawl of the latest money laundering stories. As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading →

Posted in AML, Money laundering | Tagged adverse media, AML, due diligence, financial crime, MLRO, money laundering, proceeds of crime, reputation, risk-based approach, suspicion, white collar crime | 2 Comments

Performance negated pay

Posted on July 8, 2020 by Susan Grossey author

Much has been written in recent weeks about the pandemic’s impact on AML endeavours – how to conduct CDD checks on clients who cannot leave their homes, and whether to accelerate acceptance of online CDD documents (is the risk of … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, bonus, due diligence, financial crime, MLRO, money laundering, proceeds of crime, remuneration, risk-based approach, training | Leave a comment

Nose in, fingers out

Posted on July 1, 2020 by Susan Grossey author

Recently a client asked me how to deal with difficult directors. How to train them, you mean? I asked – how to encourage them to attend AML training and take note of our pearls of wisdom? No, she said: I … Continue reading →