Category Archives: AML

Data doom and delight

Posted on June 24, 2020 by Susan Grossey author

With writing a post once a week only (I’ve fallen into writing longer posts less frequently – hope that’s OK), there’s sometimes a bit of a delay until I get round to dealing with something that’s been in the news. … Continue reading →

Posted in AML, Money laundering, Training | Tagged AML, communication, disclosure, due diligence, financial crime, government, money laundering, organised crime, Politico, proceeds of crime, research, SARs, suspicion, tax evasion | 5 Comments

A sprinkling of SAR-dust

Posted on June 17, 2020 by Susan Grossey author

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime. Does it shift the burden of investigation from law enforcement to the financial sector? Does it cost much more than it saves? Are … Continue reading →

Posted in AML, Money laundering | Tagged AML, Bank Secrecy Act, communication, disclosure, due diligence, FATF, financial crime, FinCEN, FIU, fraud, organised crime, proceeds of crime, RUSI, SARs, suspicion, suspicious activity report | Leave a comment

A most tempting offer

Posted on June 10, 2020 by Susan Grossey author

The name of my company is the result of a family joke: my father observed one day that I was always thinking about crime. I wasn’t sure I’d be allowed to have the name but I was, and it’s memorable … Continue reading →

Posted in AML, Due diligence, Fraud, Money laundering | Tagged AML, disclosure, due diligence, financial crime, fraud, money laundering, proceeds of crime, research, suspicion, Thinking about Crime Limited, white collar crime | 5 Comments

Webinar woes

Posted on June 3, 2020 by Susan Grossey author

Like many of you, I am trying to ensure that I keep my skills and knowledge as current as I can. I don’t have CPD obligations, but it’s easy to get stale or set in our ways, and there is … Continue reading →

Posted in AML, Money laundering, Training | Tagged AML, communication, due diligence, money laundering, publications, research, training, webinar | 4 Comments

Leak technique

Posted on May 27, 2020 by Susan Grossey author

I’ve been doing some remote training recently for a new MLRO, which has been great fun: we’ve covered all the essential and then plenty of those fun, tangential topics that concern MLROs – including beneficial ownership and (our topic for … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, disclosure, due diligence, financial crime, ICIJ, International Consortium of Investigative Journalists, money laundering, Offshore Leaks Database, organised crime, Panama Papers, Paradise Papers, PEP, proceeds of crime, research, risk-based approach, tax evasion, white collar crime | Leave a comment

The new crimino-normal

Posted on May 20, 2020 by Susan Grossey author

Much as I try to ignore it – otherwise it absorbs our every waking moment, and some of our nightmares – I do occasionally find that there is an interesting nexus between the coronavirus and money laundering. And this week … Continue reading →

Posted in AML, Money laundering | Tagged AML, bureau de change, due diligence, financial crime, money laundering, MSBs, National Crime Agency, NCA, organised crime, proceeds of crime | 2 Comments

Calculators at the ready

Posted on May 13, 2020 by Susan Grossey author

Sometimes words enter your vocabulary and you can’t remember where or when you first heard them but suddenly they’re there and you’re hearing and using them all the time. I’m not talking about “lock-down” or “social distancing” or “flattening the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, bribery, corruption, due diligence, Indonesia, MLRO, money laundering, PEP, regulator, research, risk-based approach | Leave a comment

A pandemic of efficiency?

Posted on May 6, 2020 by Susan Grossey author

These are very odd times: on the one hand, my daily life has slowed considerably, with elements of “Groundhog Day” about it, while on the other it is all but impossible to keep up with the fast-changing advice and requirements … Continue reading →

Posted in AML, Money laundering | Tagged AML, due diligence, financial crime, MLRO, money laundering, publications, research, training | 1 Comment

No, no, no to UWO, UWO, UWO

Posted on April 29, 2020 by Susan Grossey author

Most of us in the world of AML have welcomed the advent of the Unexplained Wealth Order – the court order introduced by the Criminal Finances Act 2017, which can be served to compel either a PEP or someone involved … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, Azerbaijan, beneficial ownership, corruption, due diligence, financial crime, government, Kazakhstan, money laundering, National Crime Agency, NCA, PEP, Politically Exposed Person, proceeds of crime, suspicion, tax evasion, Unexplained Wealth Order, UWO | 2 Comments

Keep washing that money

Posted on April 22, 2020 by Susan Grossey author

This blog – much like its author – veers wildly between buoyancy and doom, and this week it’s the latter. Sorry about that. And it’s about the pestilence. Sorry about that too. But there’s no lock-down for criminality and I … Continue reading →