Tag Archives: PEP

Wolves crying wolf

Posted on June 8, 2021 by Susan Grossey author

I’m a bit wary of wading into this topic, as I am something of a dunce when it comes to working out political affiliations and machinations – even after watching a gazillion series of “The West Wing”, I’m still not … Continue reading →

Posted in Uncategorized | Tagged AML, conviction, corruption, money laundering, Nicaragua, PEP, Politically Exposed Person, Transparency, Uganda | 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 →

Posted in Uncategorized | Tagged AML, guidance, guidance notes, legislation, MLRO, Money Laundering Regulations, PEP, source of funds, source of wealth | Leave a comment

Back to school

Posted on February 24, 2021 by Susan Grossey author

When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day … Continue reading →

Posted in Uncategorized | Tagged AML, bribery, CDD, corruption, money laundering, monitoring, National Crime Agency, NCA, OCCRP, PEP, Russian Laundromat, Transparency International | 6 Comments

Name and shame

Posted on February 10, 2021 by Susan Grossey author

We’re all used to lists and databases. There are sanctions screening systems and PEP screening systems. Within their organisations, MLROs have access to client databases. And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership … Continue reading →

Posted in Uncategorized | Tagged beneficial ownership, CDD, due diligence, Magnitsky Act, MLRO, PEP, Politically Exposed Person, register, sanctions, screening | 4 Comments

Head, brick wall, etc.

Posted on January 6, 2021 by Susan Grossey author

I first started designing and delivering AML training in 1996. That’s a full quarter-century ago. And can you imagine how many times I have said, over those twenty-five years, things like “check regularly for PEPs – regulators are hot on … Continue reading →

Posted in Uncategorized | Tagged AML, FCA, Financial Conduct Authority, Guernsey, guidance, money laundering, PEP, Politically Exposed Person, regulator, source of funds | 5 Comments

Ho-ho-ho and CDD

Posted on December 23, 2020 by Susan Grossey author

I am assuming that one or two of you might be at work today, so let us turn our AML minds to an important seasonal matter: conducting CDD on Father Christmas. For this particular individual even the most basic identity … Continue reading →

Posted in Uncategorized | Tagged CDD, Christmas, client due diligence, corruption, due diligence, enhanced due diligence, FATF, identity, PEP, Politically Exposed Person, source of funds, source of wealth | 6 Comments

Great-grandpapa’s billions

Posted on December 2, 2020 by Susan Grossey author

Like many of you, I have been reading “Kleptopia” by investigative reporter Tom Burgis. It’s both wonderfully well-written and terrifically depressing. If there’s a British PM in the past twenty years who hasn’t been advising foreign kleptocrats on how to … Continue reading →

Posted in Uncategorized | Tagged "Kleptopia", AML, CDD, due diligence, kleptocrat, MLRO, money laundering, PEP, proceeds of crime, seizure, source of wealth, Tom Burgis, white collar crime | 1 Comment

Latest leak lessons

Posted on September 23, 2020 by Susan Grossey author

This is a tricky time to write a blog post, as everywhere is swirling with stories from the “FinCEN Files”. I have explored the leaks on the ICIJ website, read the reputable (and disreputable) press sources and watched the “Panorama” … Continue reading →

Posted in AML, Money laundering, White collar crime | Tagged AML, communication, corruption, due diligence, Economist, financial crime, government, legislation, MLRO, money laundering, organised crime, Panorama, PEP, proceeds of crime, research, SARs, suspicion, suspicious activity report, white collar crime | 4 Comments

Is that why it’s called a PEP rally?

Posted on August 26, 2020 by Susan Grossey author

I am of An Age where every working surface in our house has been equipped with a cheap pair of reading glasses – who knows when I will need to read that care label, cooking instruction or baffling piece of … Continue reading →