Category Archives: Bribery and corruption

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

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

More Bloody Embezzlement?

Posted on March 4, 2020 by Susan Grossey author

Just like police officers, customs officers and passport officers, MLROs find themselves doing a certain amount of profiling when it comes to looking for high risk clients. We know about certain high risk occupations and high risk nationalities and even … Continue reading →

Posted in Bribery and corruption, Money laundering, White collar crime | Tagged AML, charities, due diligence, financial crime, money laundering, proceeds of crime, risk, risk assessment, suspicion, white collar crime | 4 Comments

I beg your pardon

Posted on February 26, 2020 by Susan Grossey author

Baron Black of Crossharbour is not my favourite person, as you may imagine, and it was a dark day in May 2019 when Donald Trump granted him a full pardon, citing Black’s “broad support from many high-profile individuals who have … Continue reading →

Posted in Bribery and corruption, White collar crime | Tagged bribery, corruption, Donald Trump, FBI, financial crime, fraud, government, money laundering, PEP, proceeds of crime, tax evasion, white collar crime | 5 Comments

Free for all

Posted on February 19, 2020 by Susan Grossey author

Just as Voldemort’s name cannot be used for fear of conjuring him up, so too we have declared a taboo in our house on the B word (the one to do with the EU) and on the name of the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering, Organised crime, Supervision, Tax | Tagged AML, Brexit, corruption, due diligence, financial crime, freeport, legislation, money laundering, organised crime, proceeds of crime, risk assessment, tax evasion, white collar crime | 6 Comments

The smile on the crocodile

Posted on October 2, 2019 by Susan Grossey author

As regular readers will know, last month I spent two weeks in Botswana, on safari. We saw all the usual amazing beasts (elephants using their trunks as snorkels!), but perhaps the most alarming were the crocodiles – enormous, prehistoric and … Continue reading →

Posted in Bribery and corruption, Money laundering | Tagged asset forfeiture, bribery, corruption, financial crime, government, money laundering, PEP, proceeds of crime, Republic of Congo, San Marino, Sassou Nguesso | 2 Comments

Exceeding slow

Posted on June 26, 2019 by Susan Grossey author

You remember the summer of ’98. The European Central Bank was founded in Brussels, Pete Sampras won the men’s singles title at Wimbledon, “Sex and the City” premiered on the telly – and Nigerian dictator Sani Abacha died at the … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, asset forfeiture, bribery, corruption, financial crime, government, Jersey, money laundering, Nigeria, PEP, proceeds of crime, Sani Abacha | 1 Comment

Los Pinos of Sherwood Forest

Posted on May 29, 2019 by Susan Grossey author

Robin Hood, Robin Hood, riding through the glen – I bet you’re all humming now. And even though historians have suggested that our Robin was not quite the champion of the poor we choose to believe, the legend persists – … Continue reading →

Posted in Bribery and corruption, Money laundering, White collar crime | Tagged AML, asset forfeiture, corruption, financial crime, government, Mexico, money laundering, organised crime, PEP, proceeds of crime, white collar crime | 3 Comments

Best foot forward

Posted on April 10, 2019 by Susan Grossey author

In recent weeks I have worked in Guernsey and Jersey and I am rather fond of both places – not least because they have rather strict AML regimes, and you know how I feel about taking AML jolly seriously. Despite … Continue reading →

Posted in AML, Bribery and corruption, Money laundering, Publications, Uncategorized | Tagged AML, CDD, corruption, Corruption Perceptions Index, due diligence, Guernsey, Isle of Man, Jersey, money laundering, PEP | 6 Comments

Adding some blacking to the UK pot

Posted on February 6, 2019 by Susan Grossey author

Any crime that generates money can lead to money laundering, but one of the biggies – and one of the most worrying for governments, with its reputational implications – is corruption. We tend of think of high-level, regime-toppling corruption (naming … Continue reading →