Category Archives: Uncategorized

Boxed into a corner

Posted on October 6, 2021 by Susan Grossey author

What else could I write about this week except the Pandora Papers? The initial focus will be on the individuals named in the leak, but away from the gory headlines will be the real work: looking at the enablers. The … Continue reading →

Posted in Uncategorized | Tagged AML, beneficial ownership, ICIJ, International Consortium of Investigative Journalists, money laundering, Panama Papers, Pandora Papers, Paradise Papers, professional enabler, Tax, Tax Justice Network, Transparency International | 2 Comments

Less than super-vision

Posted on September 29, 2021 by Susan Grossey author

I assume most of you know how I feel about the theory of OPBAS – i.e. that the solution to the fragmented and conflicting AML/CFT supervision arrangements in the UK is not to rationalise the number of supervisors but rather … Continue reading →

Posted in Uncategorized | Tagged AML, AML/CFT, due diligence, FCA, financial crime, Gambling Commission, HM Treasury, HMRC, money laundering, OPBAS, professional body supervisor, risk-based approach, supervision, supervisor | 1 Comment

A mammoth task for the MLRO

Posted on September 22, 2021 by Susan Grossey author

A little while ago I was giving a training session and used an analogy that the people attending found useful and amusing. And, being both vain and generous, I thought I would share it in case it helps with your … Continue reading →

Posted in Uncategorized | Tagged CDD, client due diligence, compliance, customer due diligence, MLRO, training | 2 Comments

A bid for freedom

Posted on September 15, 2021 by Susan Grossey author

Woohoo, I do love a good helping of Schadenfreude, and to this end one of my favourite things is hearing about what happens to the fancy assets of criminals when they are taken away (both the assets and the criminals). … Continue reading →

Posted in Uncategorized | Tagged AML, assets, auction, confiscation, financial crime, forfeiture, money laundering, police, proceeds of crime, seizure | 2 Comments

Frown and gown

Posted on September 8, 2021 by Susan Grossey author

I loved being a university student. I liked pedalling around on my bike, modelling my road positioning, arm signals and indeed wardrobe on those of Miss Jean Brodie (in her prime, gels, as the first two minutes of the movie … Continue reading →

Posted in Uncategorized | Tagged AML, art market participant, communication, due diligence, financial crime, High Value Dealer, legislation, money laundering, proceeds of crime, universities, university | Leave a comment

Could do better

Posted on August 25, 2021 by Susan Grossey author

One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading →

Posted in Uncategorized | Tagged AML, business risk assessment, CDD, FCA, Financial Conduct Authority, MLRO, PEPs, Regulations, reporting, risk, SARs, suspicion, training | Leave a comment

The Emirate strikes back

Posted on August 18, 2021 by Susan Grossey author

MLROs are used to reacting to lists and warnings issued by governments and by agencies such as the FATF. But when things change rapidly in a jurisdiction, it may be unwise to wait for an official notification, and more sensible … Continue reading →

Posted in Uncategorized | Tagged MLRO, Financial Action Task Force, FATF, enhanced due diligence, EDD, APG, high risk jurisdiction, Afghanistan, mutual evaluation report, MER, Asia/Pacific Group on Money Laudering, Tunisia, Turkey | Leave a comment

You’d need Speedy Gonzales for all this

Posted on August 11, 2021 by Susan Grossey author

The pandemic has put many things on hold – holidays, weddings, house moves – but not the requirement to provide staff with AML/CFT training. As we head towards September, and people’s minds turn towards a new school term, I am … Continue reading →

Posted in Uncategorized | Tagged AML, communication, due diligence, financial crime, GFSC, Guernsey, Guernsey Financial Services Commission, legislation, money laundering, regulator, training | Leave a comment

Undue influence

Posted on August 4, 2021 by Susan Grossey author

I’m of an age when the people I admired in my youth were known as “role models” – for me, people like Olivia Newton-John and Indira Gandhi (I had wide-ranging interests and confused professional ambitions – should I top the … Continue reading →

Posted in Uncategorized | Tagged AML, cash, cash smuggling, financial crime, fraud, influencer, money laundering, organised crime, proceeds of crime, smuggling, theft, US Attorney's Office | Leave a comment

Give me a break

Posted on July 28, 2021 by Susan Grossey author

I struggle to think of many good things to come out of the pandemic apart from a fabulous recipe for squishy chocolate chip cookies that I unearthed in desperation after the closure of my usual source. However, it has afforded … Continue reading →