Tag Archives: equivalence

An ugly new word: de-risking

Posted on August 26, 2014 by Susan Grossey author

Over the past few years, we in AML have grown used to new terms. We’ve learnt to leave behind KYC, and concentrate instead on CDD, to replace STRs with SARs. While taking on board the risk-based approach (another new term), … Continue reading →

Posted in AML, Due diligence | Tagged AML, due diligence, equivalence, FATF, government, MLRO, money laundering, PEP, risk, risk-based approach | 3 Comments

Unlike football, UK up and Spain down

Posted on December 3, 2013 by Susan Grossey author

It’s here, it’s here! No, not Sinterklaas in the Low Countries, but the annual Corruption Perceptions Index from Transparency International, published this morning. Featuring on the CPI 2013 are 177 countries – still no Guernsey, Jersey, Isle of Man, Gibraltar … Continue reading →

Posted in Bribery and corruption, Money laundering | Tagged AML, asset forfeiture, Bribery Act 2010, corruption, due diligence, equivalence, financial crime, money laundering, organised crime, PEP, proceeds of crime, tax evasion, Transparency International, white collar crime | 3 Comments

… And known close associates

Posted on November 29, 2013 by Susan Grossey author

I think we can all agree that 2013 has been something of an anno expectatio for the Vatican. In May 2013 their FIU (the Autorità di Informazione Finanziaria, or AIF) published its first annual report – rather short on detail but long … Continue reading →

Posted in AML, Due diligence, Money laundering, Supervision | Tagged AML, corruption, due diligence, equivalence, FATF, Financial Action Task Force, financial crime, money laundering, organised crime, proceeds of crime, tax evasion, Vatican | Leave a comment

Listing to starboard

Posted on November 27, 2013 by Susan Grossey author

As every MLRO can recite in his sleep, there are four elements to money laundering risk analysis: customer risk, product risk, delivery channel risk, and jurisdiction risk. Only by looking at all four of these can you come up with … Continue reading →

Posted in AML, Money laundering | Tagged AML, communication, corruption, due diligence, equivalence, FATF, Financial Action Task Force, money laundering, PEP, proceeds of crime | 3 Comments

Just who will the aid money aid?

Posted on November 13, 2013 by Susan Grossey author

With the headlines full of Typhoon Haiyan, people’s minds turn inevitably – and rightly – to aid donations. But when a country like the Philippines is involved, AML people’s minds turn inevitably to questions about corruption: bluntly, is it safe … Continue reading →

Posted in Bribery and corruption, Money laundering, Organised crime | Tagged AML, asset forfeiture, bribery, corruption, equivalence, financial crime, government, money laundering, organised crime, PEP, proceeds of crime, white collar crime | 4 Comments

Keeping up with the Vidamours, the Smiths and the Quayles

Posted on October 18, 2013 by Susan Grossey author

A while ago, I confessed to my addiction to consultations. Give me the chance to have my say, and I’m there, all opinions blazing. This past summer there was quite a rash of them (consultations, not opinions), including one issued … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, equivalence, financial crime, Guernsey, Isle of Man, Jersey, legislation, money laundering, proceeds of crime, research | 6 Comments

All created equal

Posted on October 2, 2013 by Susan Grossey author

This may be something of an understatement, but it’s not been a good year for the banks, has it? First there was that little local difficulty with a global meltdown of the banking system, along with complete destruction of public … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, due diligence, equivalence, financial crime, ML Regulations, money laundering, proceeds of crime, suspicion | 1 Comment

How do you talk to someone about their BO?

Posted on September 6, 2013 by Susan Grossey author

No, not that particular problem: thanks to the proliferation of manly deodorants called things like Overlord or Hunkmeister, plus aircon, the problem of the whiffy colleague has generally gone. I’m talking about that other unmentionable: beneficial ownership. With the revision … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, beneficial ownership, communication, disclosure, due diligence, equivalence, financial crime, money laundering, organised crime, PEP, proceeds of crime, white collar crime | Leave a comment

Damned if they do, fined if they don’t

Posted on July 23, 2013 by Susan Grossey author

Poor old Barclays. On 10 July 2013, it was reported that the bank had decided to close about a hundred accounts held by various money service businesses which regularly send money to Somalia, because of (to quote the BBC article) … Continue reading →

Posted in AML, Money laundering | Tagged AML, corruption, disclosure, due diligence, equivalence, FATF, Financial Action Task Force, financial crime, ML Regulations, money laundering, proceeds of crime | 3 Comments

Fowl play

Posted on March 4, 2013 by Susan Grossey author

What do you call a turkey that steps back from the precipice? A wise old bird, that’s what. Long story short, at the October 2012 meeting of the Financial Action Task Force, a statement was issued about Turkey and its … Continue reading →