Tag Archives: legislation

Top tips for MLROs

Posted on December 29, 2021 by Susan Grossey author

And so here we are: my final weekly blog post. I could think of no more fitting topic than my top five tips for MLROs, garnered over twenty-five years of working with you. Get people to care. It’s all very … Continue reading →

Posted in Uncategorized | Tagged AML, communication, due diligence, financial crime, legislation, MLRO, money laundering, Money Laundering Reporting Officer, proceeds of crime, training | 30 Comments

Regrets, I’ve had a few – well, OK, one

Posted on December 22, 2021 by Susan Grossey author

As I bring down the curtain on my AML life, I am reflecting in this penultimate post on what I have achieved, the direction my career has taken, and any opportunities missed. To be honest – and this might come … Continue reading →

Posted in Uncategorized | Tagged AML, communication, financial crime, guidance, JMLIT, legislation, MLRO, money laundering, RUSI, training | 8 Comments

Another disappointing report card

Posted on December 1, 2021 by Susan Grossey author

You know only too well my views (here and here, for instance) on the ridiculously over-crowded AML supervisory “space” in the UK: we have three statutory supervisors (the Financial Conduct Authority, HMRC and the Gambling Commission) and then 22 “professional … Continue reading →

Posted in Uncategorized | Tagged AML, due diligence, Economic Crime Plan, FATF, FCA, Financial Conduct Authority, Gambling Commission, HMRC, legislation, money laundering, mutual evaluation report, OPBAS, supervision | 2 Comments

Please release me

Posted on November 17, 2021 by Susan Grossey author

The principle of mitigation is an important one in the justice system. Once someone has pleaded guilty to an offence – or been found guilty of it after a trial – the attention of the court turns to sentencing, and … Continue reading →

Posted in Uncategorized | Tagged AML, cash, financial crime, legislation, money laundering, organised crime, proceeds of crime, sentence | Leave a comment

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 →

Posted in Uncategorized | Tagged AML, art market participant, communication, due diligence, financial crime, High Value Dealer, legislation, money laundering, proceeds of crime, universities, university | Leave a comment

You’d need Speedy Gonzales for all this

Posted on August 11, 2021 by Susan Grossey author

The pandemic has put many things on hold – holidays, weddings, house moves – but not the requirement to provide staff with AML/CFT training. As we head towards September, and people’s minds turn towards a new school term, I am … Continue reading →

Posted in Uncategorized | Tagged AML, communication, due diligence, financial crime, GFSC, Guernsey, Guernsey Financial Services Commission, legislation, money laundering, regulator, training | Leave a comment

If money laundering were legal…

Posted on July 21, 2021 by Susan Grossey author

Well, I’m back, having spent a week in the Suffolk countryside, which encourages a slowing of the pace and a contemplating of the navel. Just before I went away, a fellow AML enthusiast called Dev Odedra posed this question in … Continue reading →

Posted in Uncategorized | Tagged AML, due diligence, financial crime, legislation, MLRO, money laundering, proceeds of crime, tax avoidance, tax efficiency, tax evasion | 7 Comments

Lifelong learning

Posted on June 2, 2021 by Susan Grossey author

At the start of my working life, I did a self-assessment questionnaire which indicated that my strengths lay in keeping myself to myself (a team worker I ain’t) and in learning more and more about less and less – in … Continue reading →

Posted in Uncategorized | Tagged AML, anti-money laundering, cryptocurrencies, FATF, Financial Action Task Force, legislation, MLRO, money laundering, Money Laundering Reporting Officer, trade-based money laundering | Leave a comment

Gone but not un-rotten

Posted on April 28, 2021 by Susan Grossey author

Last week a client asked me a question about dead PEPs, and in looking for the answer I realised that this is not a topic addressed by the regulator. Which is odd, given that it is the inevitable final status … Continue reading →

Posted in Uncategorized | Tagged AML, bribery, corruption, Guernsey, guidance, legislation, LinkedIn, money laundering, PEP, Politically Exposed Person, risk-based approach | Leave a comment

Hang on every word

Posted on March 10, 2021 by Susan Grossey author

I have been called pedantic, but that’s not strictly accurate. The fact is that I make my living from – and spend much of my leisure time with – words. Most compliance-y people are good at detail: at school we … Continue reading →