Tag Archives: due diligence

Top tips for MLROs

Posted on December 29, 2021 by Susan Grossey author

And so here we are: my final weekly blog post. I could think of no more fitting topic than my top five tips for MLROs, garnered over twenty-five years of working with you. Get people to care. It’s all very … Continue reading →

Posted in Uncategorized | Tagged AML, communication, due diligence, financial crime, legislation, MLRO, money laundering, Money Laundering Reporting Officer, proceeds of crime, training | 30 Comments

Another disappointing report card

Posted on December 1, 2021 by Susan Grossey author

You know only too well my views (here and here, for instance) on the ridiculously over-crowded AML supervisory “space” in the UK: we have three statutory supervisors (the Financial Conduct Authority, HMRC and the Gambling Commission) and then 22 “professional … Continue reading →

Posted in Uncategorized | Tagged AML, due diligence, Economic Crime Plan, FATF, FCA, Financial Conduct Authority, Gambling Commission, HMRC, legislation, money laundering, mutual evaluation report, OPBAS, supervision | 2 Comments

Underfunded, under-supervised and over here

Posted on November 3, 2021 by Susan Grossey author

I know, I know: who thought I would spend my last few months as an AML-er shaking my fist impotently at the madness that is freeports? But here we are. I’ve written before (here and here) about why they’re such … Continue reading →

Posted in Uncategorized | Tagged AML, anti-money laundering, due diligence, financial crime, freeport, HMRC, money laundering, organised crime, proceeds of crime, smuggling, tax evasion | Leave a comment

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

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

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

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 →

Posted in Uncategorized | Tagged AML, compliance, due diligence, financial crime, MLRO, money laundering | Leave a comment

If money laundering were legal…

Posted on July 21, 2021 by Susan Grossey author

Well, I’m back, having spent a week in the Suffolk countryside, which encourages a slowing of the pace and a contemplating of the navel. Just before I went away, a fellow AML enthusiast called Dev Odedra posed this question in … Continue reading →

Posted in Uncategorized | Tagged AML, due diligence, financial crime, legislation, MLRO, money laundering, proceeds of crime, tax avoidance, tax efficiency, tax evasion | 7 Comments

I beg your pardon

Posted on February 17, 2021 by Susan Grossey author

In the last few days of the presidency of Donald Trump, when he was granting pardons to his chums and executing three black men and a woman while his mob was looting the Capitol, I read a tweet that has … Continue reading →

Posted in Uncategorized | Tagged AML, CDD, drug trafficking, due diligence, fit and proper, money laundering, white collar crime | Leave a comment

Name and shame

Posted on February 10, 2021 by Susan Grossey author

We’re all used to lists and databases. There are sanctions screening systems and PEP screening systems. Within their organisations, MLROs have access to client databases. And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership … Continue reading →