Tag Archives: MLD5

I long for a Verwijzingsportaal Bankgegevens

Posted on October 27, 2021 by Susan Grossey author

Apologies for the unexpectedly long silence: I was felled by covid. Thankfully I am on the mend and once more have enough energy for outrage and indignation. I had a Dutch boyfriend for several years, during which time I developed … Continue reading →

Registering my displeasure

Posted on May 12, 2021 by Susan Grossey author

When I was a schoolgirl, in the late Victorian era, BO had a different meaning: if some poor soul had BO, you flapped your hand in front of your nose and worked the word “deodorant” into your conversation with them … Continue reading →

Posted in Uncategorized | Tagged AML, beneficial ownership, FIU, Guernsey, Guernsey Registry, MLD5, money laundering, PSC register | Leave a comment

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

Sixth sense

Posted on September 16, 2020 by Susan Grossey author

Right, here’s a little quiz for you: as of today, it’s 78 days until what? Points deducted if you simply say, “Thursday 3 December” – although points added if you know that that’s my mother-in-law’s birthday [note to self: remind … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, Fifth Money Laundering Directive, financial crime, government, legislation, MLD5, MLD6, money laundering, organised crime, proceeds of crime, Sixth Money Laundering Directive, tax evasion | 6 Comments

Taking money laundering to ‘art

Posted on January 29, 2020 by Susan Grossey author

“I don’t know much about art, but I know what I like.” That (very common) attitude might be OK when you’re standing in a gallery trying to make sense of something you’ve seen, but it won’t pass muster if you’re … Continue reading →

Posted in AML, Legislation, Money laundering | Tagged AML, art, art market participant, due diligence, Fifth Money Laundering Directive, financial crime, freeport, legislation, MLD5, MLRO, money laundering, Money Laundering Regulations, organised crime, proceeds of crime, training | 2 Comments

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

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

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 →