Tag Archives: equivalence

Desperately seeking Regulations

Posted on November 25, 2020 by Susan Grossey author

* Alert!  This is a long, ranty post – you may need a Jaffa Cake or two to stay the course…* I’m quite bright.  Not “University Challenge” winning team bright, but I have a couple of degrees, I can sometimes … Continue reading →

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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 →

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A return to the bad old days

Posted on March 5, 2018 by Susan Grossey author

You all know how I feel about Brexit, so we shall draw a discreet veil over the months of wailing and gnashing of teeth and rending of garments that have befallen Grossey Mansions.  However, as I had feared, we are … Continue reading →

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Game for AML

Posted on October 14, 2016 by Susan Grossey author

At some training recently, we had finished the serious business of the day and were cruising into the home straight with a quick round of my Countries Quiz.  As I was asking people to match capital cities to countries, one … Continue reading →

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Who’s on the FATF’s naughty step?

Posted on July 1, 2016 by Susan Grossey author

So the FATF’s latest take on their list of naughty countries – or, more properly, those jurisdictions with strategic AML/CFT deficiencies – is out.  Their latest plenary meeting, this time in Busan in Korea, ended on 24 June 2016, and … Continue reading →

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Jumping on the Brexit bandwagon

Posted on March 29, 2016 by Susan Grossey author

Having last week been accused of (or congratulated on – I couldn’t quite tell) being political, I thought I might as well go with the flow.  About three weeks ago I was doing some training in London, talking about the … Continue reading →

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Levels of concern

Posted on March 11, 2016 by Susan Grossey author

I like reliable.  I know reliable isn’t exciting, but I’ve always preferred it to unpredictable or ad hoc.  And my byword for reliability is the “International Narcotics Control Strategy Report” which is published by the US Department of State every … Continue reading →

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Joining the club

Posted on February 29, 2016 by Susan Grossey author

There is always plenty to consider after an FATF plenary meeting, and the most recent one is no exception.  At their end of their meeting in Paris on 19 February, the FATF announced two additions to their membership: Malaysia has … Continue reading →

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Beware the EU shortcut

Posted on October 29, 2015 by Susan Grossey author

When MLROs are populating their lists of high- and low-risk jurisdictions, they are advised to consult as wide a range of (reputable) sources as possible.  (For non-MLRO readers, the risk status of a jurisdiction matters because if it is judged … Continue reading →

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Checking your seatbelt

Posted on February 12, 2015 by Susan Grossey author

It would be remiss of me to let “the HSBC situation” go by without comment.  I may well return to it in future, as I know some of the people involved and will try to get some MLRO-relevant details from … Continue reading →

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