Tag Archives: disclosure

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

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 stink of money laundering

Posted on October 9, 2019 by Susan Grossey author

Have you ever fibbed slightly about what you do for a living (that you work in AML) in order to avoid yet another tedious story about someone’s grandma who was with her bank for 312 years and STILL had to … Continue reading →

Posted in AML, Money laundering | Tagged AML, Barclays, disclosure, due diligence, financial crime, money laundering, National Crime Agency, NCA, organised crime, proceeds of crime, Tony Hetherington | 9 Comments

The plain un-SAR-nished truth

Posted on March 6, 2019 by Susan Grossey author

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS? “Ruthless trained killers are just a … Continue reading →

Posted in AML, Money laundering, Organised crime, Supervision | Tagged AML, disclosure, due diligence, FATF, Financial Conduct Authority, financial crime, FIU, government, National Crime Agency, National Risk Assessment, NCA, SARs, Solicitors Regulation Authority | 8 Comments

Cleaning house

Posted on February 27, 2019 by Susan Grossey author

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, beneficial ownership, Companies House, disclosure, due diligence, FATF, financial crime, government, legislation, money laundering, publications, research, RUSI | 4 Comments

Officer politics

Posted on January 30, 2019 by Susan Grossey author

One of my main arenas of AML activity is Guernsey, and life there is pretty exciting at the moment with the imminent arrival of new AML legislation and guidance – both already published and coming into force on 31 March … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, disclosure, due diligence, financial crime, government, Guernsey, Jersey, legislation, MLCO, MLRO, Money Laundering Compliance Officer, Money Laundering Regulations, Money Laundering Reporting Officer, nominated officer | 3 Comments

The concept of anonymous publication

Posted on December 12, 2018 by Susan Grossey author

We all have a talent, and mine is words. I love reading and writing them, my spelling is pretty crash-hot, and if I am trying to remember something, I tend to see it as a word, e.g. “I’ve forgotten his … Continue reading →

Posted in AML, Money laundering, Supervision | Tagged AML, communication, disclosure, due diligence, FCA, Financial Conduct Authority, Gambling Commission, government, Guernsey Financial Services Commission, HMRC, ML Regulations, money laundering, publications | 4 Comments

Nostra culpa

Posted on July 20, 2018 by Susan Grossey author

I take no credit at all for spotting this – it’s all down to Timon Molloy, editor and super-sleuth at Money Laundering Bulletin. But my new favourite financial institution is Danske Bank. Now I know what you’re thinking: surely they’re … Continue reading →