Tag Archives: MLD4

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

FATF 1, EU 0

Posted on July 17, 2019 by Susan Grossey author

The Fourth Money Laundering Directive brought us many delights, including Article 9: “Third-country jurisdictions which have strategic deficiencies in their national AML/CFT regimes that pose significant threats to the financial system of the Union (‘high-risk third countries’) shall be identified … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, communication, due diligence, European Commission, European Union, FATF, Financial Action Task Force, government, legislation, MLD4, MLD5, money laundering, publications | 5 Comments

Keeping up with the Joneses, les Dubois and die Schmidts

Posted on December 7, 2018 by Susan Grossey author

I mentioned in my previous post that Guernsey is on the cusp, nay, the very brink of getting new AML legislation. This represents the conclusion of their exercise to fall into line with the Fourth Money Laundering Directive (or as … Continue reading →

Posted in AML, Legislation | Tagged AML, directive, guidance, MLD4, MLD5, MLD6, money laundering, Money Laundering Directive, supervisor | Leave a 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

The luxury of dithering

Posted on August 16, 2016 by Susan Grossey author

So here I am, back from my summer writing retreat, and normal blogging has resumed. It was quite a relief to be out of the country – in Switzerland, to be precise – and get away from all the Brexit … Continue reading →

Posted in AML, Legislation, Uncategorized | Tagged AML, financial crime, government, legislation, ML Regulations, MLD4, MLRO, money laundering, PEP, training | Leave a comment

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 →

Posted in AML, Legislation, Money laundering | Tagged AML, due diligence, financial crime, government, High Value Dealer, legislation, MLD4, money laundering, proceeds of crime | 11 Comments

At your service

Posted on October 1, 2014 by Susan Grossey author

Last week I was updating several clients on the progress of the Fourth Money Laundering Directive, highlighting for them the changes that I have noticed. Most proposed changes have received plenty of attention – PEP definition, register of beneficial ownership, … Continue reading →