Tag Archives: corruption

A new chapter for financial crime

Posted on July 7, 2021 by Susan Grossey author

When you live in a country with a Prime Minister who is alleged to have said in April 2021 that he would rather see “bodies pile high in their thousands” than order a third lockdown, and who now confirms that “we … Continue reading →

Posted in Uncategorized | Tagged abuse, AML, Chancellor, corruption, financial crime, fraud, HM Treasury, HMG, MLRO, money laundering, regulation, risk-based approach | Leave a comment

Wolves crying wolf

Posted on June 8, 2021 by Susan Grossey author

I’m a bit wary of wading into this topic, as I am something of a dunce when it comes to working out political affiliations and machinations – even after watching a gazillion series of “The West Wing”, I’m still not … Continue reading →

Posted in Uncategorized | Tagged AML, conviction, corruption, money laundering, Nicaragua, PEP, Politically Exposed Person, Transparency, Uganda | Leave a comment

Calling a spade an earth spoon

Posted on May 5, 2021 by Susan Grossey author

If you’re a fan of the current UK government – and particularly the Eton mess whose name shall not be spoken – I suggest you stop reading now. For my part, I consider them a corrupt regime equal to that … Continue reading →

Posted in Uncategorized | Tagged AML, corruption, Good Law Project, government, kleptocracy, money laundering, tax evasion, Transparency International | 2 Comments

Gone but not un-rotten

Posted on April 28, 2021 by Susan Grossey author

Last week a client asked me a question about dead PEPs, and in looking for the answer I realised that this is not a topic addressed by the regulator. Which is odd, given that it is the inevitable final status … Continue reading →

Posted in Uncategorized | Tagged AML, bribery, corruption, Guernsey, guidance, legislation, LinkedIn, money laundering, PEP, Politically Exposed Person, risk-based approach | Leave a comment

Back to school

Posted on February 24, 2021 by Susan Grossey author

When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day … Continue reading →

Posted in Uncategorized | Tagged AML, bribery, CDD, corruption, money laundering, monitoring, National Crime Agency, NCA, OCCRP, PEP, Russian Laundromat, Transparency International | 6 Comments

Ho-ho-ho and CDD

Posted on December 23, 2020 by Susan Grossey author

I am assuming that one or two of you might be at work today, so let us turn our AML minds to an important seasonal matter: conducting CDD on Father Christmas. For this particular individual even the most basic identity … Continue reading →

Posted in Uncategorized | Tagged CDD, Christmas, client due diligence, corruption, due diligence, enhanced due diligence, FATF, identity, PEP, Politically Exposed Person, source of funds, source of wealth | 6 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

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

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 →