Tag Archives: ML Regulations

The sniff test

Posted on February 5, 2020 by Susan Grossey author

The relationship between jewellers and the AML regime is a complicated one. For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of … Continue reading →

Posted in AML, Money laundering | Tagged AML, due diligence, financial crime, legislation, ML Regulations, MLRO, money laundering, proceeds of crime, suspicion, tax evasion | 9 Comments

A piggy new year to everyone

Posted on January 8, 2020 by Susan Grossey author

Welcome back, one and all. Well, wasn’t that an exciting festive period? Just as I was undoing the top button on my skirt, ready to launch into the yard of Jaffa Cakes that my husband (he knows me so well) … Continue reading →

Posted in AML, Legislation, Money laundering, Publications | Tagged AML, due diligence, financial crime, government, legislation, ML Regulations, money laundering, publications, training, writing | 6 Comments

Take my word for it

Posted on December 18, 2019 by Susan Grossey author

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, corporate service provider, due diligence, equivalence, financial crime, government, legislation, ML Regulations, MLRO, money laundering, reliance, research, risk-based approach, Transparency International | 1 Comment

Asking for trouble

Posted on May 1, 2019 by Susan Grossey author

When Brexit is simply too, too depressing, I remind myself that in my own little world at least nothing much is changing. Cambridge – where I live – is as cosmopolitan and outward-looking as ever, and the Fifth Money Laundering … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, financial crime, government, legislation, ML Regulations, MLD5, money laundering, proceeds of crime, risk-based approach | 2 Comments

The Brexit bonanza for baddies

Posted on February 13, 2019 by Susan Grossey author

You have probably guessed from recent tear-stained posts that I am not a fan of Brexit. Having lived an international life surrounded – very happily – by people from all over the world, I rear up at the thought of … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, Brexit, communication, due diligence, financial crime, government, legislation, ML Regulations, money laundering, National Crime Agency, NCA, organised crime, proceeds of crime | 7 Comments

The concept of anonymous publication

Posted on December 12, 2018 by Susan Grossey author

We all have a talent, and mine is words. I love reading and writing them, my spelling is pretty crash-hot, and if I am trying to remember something, I tend to see it as a word, e.g. “I’ve forgotten his … Continue reading →

Posted in AML, Money laundering, Supervision | Tagged AML, communication, disclosure, due diligence, FCA, Financial Conduct Authority, Gambling Commission, government, Guernsey Financial Services Commission, HMRC, ML Regulations, money laundering, publications | 4 Comments

Cloud cuckoo Brexit

Posted on August 27, 2018 by Susan Grossey author

Don’t worry: I’m not going to tell you again how I feel about Brexit. This update is purely about the AML implications for those of us left behind in the cast-adrift, backwards-looking, isolationist UK. As you know, the European Fifth … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, Brexit, communication, European Union, Fifth Money Laundering Directive, financial crime, government, ML Regulations, MLRO, money laundering | Leave a comment

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

Cleaning house for estate agents

Posted on January 26, 2018 by Susan Grossey author

Just to raise the tone of this blog a little, I’d like to start today with a quotation from Voltaire’s 1759 satirical novel “Candide”: “Dans ce pays-ci, il est bon de tuer de temps en temps un amiral pour encourager les … Continue reading →

Posted in AML, Money laundering, Supervision | Tagged AML, due diligence, estate agent, financial crime, HMRC, legislation, ML Regulations, money laundering, National Association of Estate Agents, supervision | 6 Comments

A rap on the online knuckles

Posted on January 8, 2018 by Susan Grossey author

AML regulation of the gambling sector in the UK is complicated; even I (writing as an AML obsessive) am sometimes confused about who is in and who is out. However, one sector that is most definitely in is online gambling, … Continue reading →