Tag Archives: FIU

I long for a Verwijzingsportaal Bankgegevens

Posted on October 27, 2021 by Susan Grossey author

Apologies for the unexpectedly long silence: I was felled by covid. Thankfully I am on the mend and once more have enough energy for outrage and indignation. I had a Dutch boyfriend for several years, during which time I developed … Continue reading →

Registering my displeasure

Posted on May 12, 2021 by Susan Grossey author

When I was a schoolgirl, in the late Victorian era, BO had a different meaning: if some poor soul had BO, you flapped your hand in front of your nose and worked the word “deodorant” into your conversation with them … Continue reading →

Posted in Uncategorized | Tagged AML, beneficial ownership, FIU, Guernsey, Guernsey Registry, MLD5, money laundering, PSC register | Leave a comment

Mind your own business

Posted on March 17, 2021 by Susan Grossey author

One of the trickier aspects of the MLRO’s job is the juggling act they have to perform to keep everyone happy – staff, Board (or whatever their firm’s top layer of control is called), regulators and investigators. Although this can … Continue reading →

Posted in Uncategorized | Tagged AML, annual report, Board, directors, FCA, FIU, guidance, JMLSG, MLRO, money laundering, nominated officer, reporting, SAR, suspicion | Leave a comment

Outside, looking in

Posted on November 11, 2020 by Susan Grossey author

Regular readers will know what a fan I am of Brexit. I think it is the work of the devil, second only to “The One Show” for its ability to take something wonderful and then ruin it for everyone. As … Continue reading →

Posted in Uncategorized | Tagged AML, EU, European Commission, European Union, FIU, MLRO, money laundering, NCA, tax evasion, white collar crime | 6 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

Looking to the post-pandemic future

Posted on April 1, 2020 by Susan Grossey author

I’m not going to attempt to foretell the impact that the current pandemic will have on our financial systems or on financial crime – there are many people much better qualified than I to do that. For instance, the tip-top … Continue reading →

Posted in AML, Money laundering, Organised crime | Tagged AML, Bright Line Law, due diligence, financial crime, FIU, legislation, money laundering, organised crime, proceeds of crime, research, risk assessment, risk-based approach, RUSI, suspicion | 11 Comments

Launderer seeks splendour without diminishment

Posted on May 15, 2019 by Susan Grossey author

It cannot have escaped your notice that Canada is in a lather about its real estate sector being used for money laundering. Stories are appearing seemingly every day about some new scheme or other that has been uncovered, thanks in … Continue reading →

Posted in AML, Money laundering, Organised crime, Uncategorized | Tagged AML, beneficial ownership, Canada, estate agent, FinTRAC, FIU, High Value Dealer, lawyer, luxury vehicles, money laundering, organised crime, real estate | 1 Comment

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

Glategny Court jester

Posted on August 8, 2018 by Susan Grossey author

“Please God don’t let it be money laundering” and “Heavens above, why can’t they get the concept of source of wealth?” may well be familiar phrases in the lexicon of the MLRO. But although a greater power – greater even … Continue reading →

Posted in AML, General thoughts, Regulation | Tagged AML, chaplain, financial crime, FIU, GFSC, Guernsey, Guernsey Financial Services Commission, ML Regulations, money laundering | Leave a comment

The cheque less travelled

Posted on July 25, 2018 by Susan Grossey author

One of the things that enticed me to write historical crime novels focusing on financial crime was the realisation – when I was doing some research into the history of a particular bank – that the specific tools may change … Continue reading →