Tag Archives: Politically Exposed Person

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

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

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 →

Posted in AML, Due diligence, Legislation, Money laundering | Tagged AML, Bank Secrecy Act, due diligence, FATF, financial crime, government, legislation, money laundering, organised crime, PEP, Politically Exposed Person, proceeds of crime, tax evasion, white collar crime | 4 Comments

No, no, no to UWO, UWO, UWO

Posted on April 29, 2020 by Susan Grossey author

Most of us in the world of AML have welcomed the advent of the Unexplained Wealth Order – the court order introduced by the Criminal Finances Act 2017, which can be served to compel either a PEP or someone involved … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, Azerbaijan, beneficial ownership, corruption, due diligence, financial crime, government, Kazakhstan, money laundering, National Crime Agency, NCA, PEP, Politically Exposed Person, proceeds of crime, suspicion, tax evasion, Unexplained Wealth Order, UWO | 2 Comments

Tainted treasures indeed

Posted on June 22, 2018 by Susan Grossey author

I have always been a swot, living mainly in my head. Physically I’ve never been much cop; I was always the one picked last – and even then, reluctantly – for sports teams, and my clumsiness is legendary. But in … Continue reading →

Posted in Bribery and corruption, Money laundering | Tagged AML, due diligence, financial crime, government, money laundering, PEP, Politically Exposed Person, proceeds of crime, publications, research, white collar crime | 4 Comments

Some are more equal than others

Posted on August 9, 2017 by Susan Grossey author

The connection between PEPs [politically exposed persons] and money laundering is recognised: with access to public influence and public money, these individuals in positions of high public service can fall prey to their baser desires and start feathering their private … Continue reading →

Posted in AML, Money laundering | Tagged bribery, corruption, financial crime, government, money laundering, PEP, Politically Exposed Person, proceeds of crime, suspicion, tax evasion | 2 Comments

Anna Karenina and the assault rifle

Posted on November 16, 2016 by Susan Grossey author

PEPs = high risk = EDD. But why? The short answer is corruption: anyone with access to public influence and/or public money will be a target for criminals who want to gain that access for themselves. Of course, the majority … Continue reading →