Tag Archives: High Value Dealer

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 →

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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 →

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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 →

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Back to school for AML

Posted on November 9, 2018 by Susan Grossey author

British public schools have a lot to answer for – David Cameron, BoJo, Michael Gove, rugby – but to this list we can now add money laundering.  I don’t want to claim any glory (well, maybe just a bit) but … Continue reading →

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Money launder-bling

Posted on September 19, 2018 by Susan Grossey author

Working in Guernsey this week, I was talking to a client about the concept of the High Value Dealer (under local legislation, those who “[trade] in goods where there is received… a payment or payments in cash of at least … Continue reading →

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One-stop knocking shop

Posted on December 1, 2015 by Susan Grossey author

Following a recent Financial Times article on money laundering through cash-intensive businesses in the UK (albeit in the “luxury sector”), a investigation in New Jersey is a timely reminder for us all about how useful to criminals are businesses that … Continue reading →

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Regulatory arbitrage

Posted on October 9, 2015 by Susan Grossey author

No, that’s not the name of a minor – probably dastardly – character in a Mills and Boon novel: it is what happens when differing standards of regulation allow criminals to wriggle their way through the system by exploiting those … Continue reading →

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Cash will do nicely, sir

Posted on June 9, 2015 by Susan Grossey author

Remember the days of “cash is king”?  It may still be handy for getting a good deal on a second-hand car, but otherwise, for those of us in the AML community, cash is a pain in the proverbial.  The Fourth Money … Continue reading →

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Wham, bam, no AML, ma’am

Posted on March 23, 2015 by Susan Grossey author

Some while ago I wrote about a draft of the Fourth Money Laundering Directive that had sneaked in a much-extended definition of “high value dealers”.  What this earlier draft said was that HVDs would be “other natural or legal persons … Continue reading →

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A blind eye for art

Posted on June 4, 2014 by Susan Grossey author

Some years ago, I was asked to do some AML training for a well-known art auction house.  I remember two things about the day: I was by far the shortest and fattest woman in the place, and everyone spoke in … Continue reading →

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