Category Archives: Due diligence

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

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

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

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

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 →

Posted in AML, Due diligence, Fraud, Money laundering, Organised crime | Tagged AML, corruption, due diligence, FBI, financial crime, fraud, mafia, money laundering, organised crime, proceeds of crime, white collar crime | 3 Comments

The launderer always blinks twice

Posted on April 8, 2020 by Susan Grossey author

My money laundering news alerts have been very, very quiet in the past fortnight – not for one moment do I think this means that money laundering has stopped, or even decreased markedly, but understandably businesses and law enforcement agencies … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, communication, due diligence, financial crime, government, Guernsey, money laundering, proceeds of crime, research, risk-based approach | 7 Comments

This time it’s personal

Posted on March 11, 2020 by Susan Grossey author

We’re fairly accustomed now to seeing firms of various stripe fined for AML failings, but for all the talk of personal accountability and statements of responsibility it is still rare for individuals to be held liable for poor AML behaviour. … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, bank, Bank Secrecy Act, due diligence, financial crime, legislation, money laundering, proceeds of crime, risk-based approach, SARs, suspicion | 2 Comments

The special joy of damage joy

Posted on January 15, 2020 by Susan Grossey author

I remember the first time I was told what schadenfreude means – pleasure derived from another’s misfortune. I quickly realised what an essential component of life it is, and thought how odd it is that only the Germans have seen … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, due diligence, financial crime, Financial Reporting Order, government, legislation, money laundering, National Crime Agency, NCA, organised crime, proceeds of crime, Serious Crime Prevention Order, Travel Restriction Order | 4 Comments

Take my word for it

Posted on December 18, 2019 by Susan Grossey author

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, corporate service provider, due diligence, equivalence, financial crime, government, legislation, ML Regulations, MLRO, money laundering, reliance, research, risk-based approach, Transparency International | 1 Comment

Lights, camera, action!

Posted on November 20, 2019 by Susan Grossey author

After my little rant about podcasts, I can report this week that conversely I am fully in favour of what I still call video clips. In the olden days, when I used videos as part of my AML training, we … Continue reading →