Tag Archives: National Risk Assessment

A welcome divorce

Posted on December 15, 2021 by Susan Grossey author

A significant change was made to my AML-ish life on 26 October 2005: on that date appeared the Third Money Laundering Directive, with the addition of “and terrorist financing” to its title, whereas First and Second had been pure money … Continue reading →

Posted in Uncategorized | Tagged AML, AML/CFT, business risk assessment, CFT, financial crime, money laundering, money service business, National Risk Assessment, terrorist financing, Third Money Laundering Directive, training | 2 Comments

Grey clouds are gathering

Posted on June 23, 2021 by Susan Grossey author

I want to talk about the FATF. First, I think it’s called the “eff-ay-tee-eff” – not “fat-fee” or (occasionally) “faft”. And second, I’m interested in the significance of their grey list (officially, their list of jurisdictions under increased monitoring). Not … Continue reading →

Posted in Uncategorized | Tagged AML, EDD, enhanced due diligence, FATF, Financial Action Task Force, high risk jurisdiction, jurisdiction, MLRO, money laundering, National Risk Assessment, SOF/SOW, source of funds, source of wealth | 5 Comments

Let’s risk it for a Brexit

Posted on December 30, 2020 by Susan Grossey author

Better late than never, I suppose – the UK’s third National Risk Assessment, due in October 2019, was finally published on 17 December 2020. When discussing risk assessment with MLROs, I describe it as a focussing exercise: you start big, … Continue reading →

Posted in Uncategorized | Tagged AML, Brexit, business risk assessment, CDD, FATF, Fourth Money Laundering Directive, legislation, MLRO, money laundering, National Risk Assessment, Recommendations, risk-based approach, sanctions | 4 Comments

Shady trade-y

Posted on December 16, 2020 by Susan Grossey author

Right at the start of my working life, just after the Industrial Revolution, I did one of those early personality tests. I’m struggling to remember what it was called (something about umbrellas, or maybe anchors?) but it was meant to … Continue reading →

Posted in Uncategorized | Tagged AML, APG, beneficial ownership, CDD, FATF, MLRO, money laundering, National Risk Assessment, NRA, TBML, trade-based money laundering | 4 Comments

The word from on high

Posted on October 7, 2020 by Susan Grossey author

Right, let’s get ready for a quick test of AML TLA [three-letter acronym]: what do the RBA, BRA, RAS and NRA all have in common? Bravo for shouting out “the letter R” – standing, of course, for Risk. As in: … Continue reading →

Posted in Uncategorized | Tagged AML, business risk assessment, FATF, Jersey, money laundering, National Risk Assessment, risk appetite, risk-based approach, terrorist financing | 2 Comments

The plain un-SAR-nished truth

Posted on March 6, 2019 by Susan Grossey author

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS? “Ruthless trained killers are just a … Continue reading →

Posted in AML, Money laundering, Organised crime, Supervision | Tagged AML, disclosure, due diligence, FATF, Financial Conduct Authority, financial crime, FIU, government, National Crime Agency, National Risk Assessment, NCA, SARs, Solicitors Regulation Authority | 8 Comments

Confession is good for the soul

Posted on November 12, 2015 by Susan Grossey author

The lovely film “Out of Africa” contains one of my favourite cinematic lines of all time. No, it’s not a declaration of love from mahogany Rob to multi-accented Meryl, but rather the response from her dastardly soon-to-be-ex-husband, the splendidly-named Baron … Continue reading →

Posted in AML, Money laundering, Publications | Tagged AML, Cayman Islands, FATF, Financial Action Task Force, legislation, money laundering, National Risk Assessment | 1 Comment

A superabundance of supervisors

Posted on October 23, 2015 by Susan Grossey author

With all eyes on the Fourth Money Laundering Directive, I will confess that I had lost track of the UK’s AML/CFT National Risk Assessment – and then it appeared last week. There’s plenty of meat in it and it’s perfectly … Continue reading →