Tag Archives: Fourth Money Laundering Directive

Faint at art

Posted on March 31, 2021 by Susan Grossey author

It’s a tricky thing, art. No – I don’t mean those arguments over whether an unmade bed or a black painted square is art, but the deliberations about when the art world is part of the AML community and when … Continue reading →

Posted in Uncategorized | Tagged AML, art, art market participant, cash, Fifth Money Laundering Directive, Fourth Money Laundering Directive, High Value Dealer, MLD4, MLD5, money laundering, National Crime Agency, National Economic Crime Centre, NCA, NECC, SARs | 1 Comment

Let’s risk it for a Brexit

Posted on December 30, 2020 by Susan Grossey author

Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020. When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading →

Posted in Uncategorized | Tagged AML, Brexit, business risk assessment, CDD, FATF, Fourth Money Laundering Directive, legislation, MLRO, money laundering, National Risk Assessment, Recommendations, risk-based approach, sanctions | 4 Comments

Moving the goalposts

Posted on December 19, 2016 by Susan Grossey author

I’m as fond of AML measures as the next person. Actually, that’s a fib: I’m probably a thousand times fonder of AML measures than the next person. But more than two decades of AML endeavours have taught me one important … Continue reading →

Posted in AML, Legislation, Money laundering, Uncategorized | Tagged AML, financial crime, Fourth Money Laundering Directive, money laundering, procedures | 1 Comment

Money laundering is on the cards

Posted on December 14, 2016 by Susan Grossey author

A couple of months ago, traffic police in Alabama stopped a car and noticed the smell of marijuana. They searched the car and found forty gift cards with a total balance of US$19,600, along with “numerous receipts showing repetitive reloading … Continue reading →

Posted in AML, Money laundering | Tagged AML, due diligence, financial crime, Fourth Money Laundering Directive, gift cards, legislation, MLD4, organised crime, prepaid cards, proceeds of crime | Leave a comment

A consultation too far?

Posted on September 26, 2016 by Susan Grossey author

Regular readers will know that I am quite taken with consultations: I like people asking my opinion nearly as much as I love giving it. I tend to respond to AML-themed ones most avidly, but in recent months I have … Continue reading →

Posted in AML, Money laundering, Publications | Tagged AML, communication, Fourth Money Laundering Directive, government, legislation, ML Regulations, MLD4, money laundering | Leave a comment

A directive date for 2017

Posted on June 11, 2015 by Susan Grossey author

It feels as though we’ve been waiting for the Fourth Money Laundering Directive for about a decade, doesn’t it? Well, I suppose we have, really, as the third one was adopted in 2005. But at long last we know what’s … Continue reading →