Tag Archives: risk-based approach

Less than super-vision

Posted on September 29, 2021 by Susan Grossey author

I assume most of you know how I feel about the theory of OPBAS – i.e. that the solution to the fragmented and conflicting AML/CFT supervision arrangements in the UK is not to rationalise the number of supervisors but rather … Continue reading →

Posted in Uncategorized | Tagged AML, AML/CFT, due diligence, FCA, financial crime, Gambling Commission, HM Treasury, HMRC, money laundering, OPBAS, professional body supervisor, risk-based approach, supervision, supervisor | 1 Comment

A new chapter for financial crime

Posted on July 7, 2021 by Susan Grossey author

When you live in a country with a Prime Minister who is alleged to have said in April 2021 that he would rather see “bodies pile high in their thousands” than order a third lockdown, and who now confirms that “we … Continue reading →

Posted in Uncategorized | Tagged abuse, AML, Chancellor, corruption, financial crime, fraud, HM Treasury, HMG, MLRO, money laundering, regulation, risk-based approach | 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

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

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

Ethics girls and boys

Posted on September 30, 2020 by Susan Grossey author

With the recent headlines concerning Mr Trump’s tax arrangements and Mr Johnson’s awarding of government contracts to chums, you can imagine that the issue of morality has been much on my mind. I come from mixed stock: one half of … Continue reading →

Posted in AML, Uncategorized, White collar crime | Tagged AML, communication, due diligence, ethics, financial crime, fraud, money laundering, research, risk-based approach, suspicion, training | 4 Comments

Happy holidays!

Posted on August 19, 2020 by Susan Grossey author

Well hello everyone – I’m back. And while I was away on my hols, I did wonder whether taking time off in the summer was the responsible thing to do. As long ago as 1831, astronomer and statistician Adolphe Quetelet … Continue reading →

Posted in AML, Fraud, Money laundering, Organised crime | Tagged AML, due diligence, financial crime, fraud, money laundering, organised crime, risk-based approach, white collar crime | Leave a comment

Friends in low places

Posted on July 15, 2020 by Susan Grossey author

For my sins, I start every working day with a trawl of the latest money laundering stories. As I scan them, I am doing mental triage: Really significant developments go onto the Newsroom page of my website Those, and other … Continue reading →

Posted in AML, Money laundering | Tagged adverse media, AML, due diligence, financial crime, MLRO, money laundering, proceeds of crime, reputation, risk-based approach, suspicion, white collar crime | 2 Comments

Performance negated pay

Posted on July 8, 2020 by Susan Grossey author

Much has been written in recent weeks about the pandemic’s impact on AML endeavours – how to conduct CDD checks on clients who cannot leave their homes, and whether to accelerate acceptance of online CDD documents (is the risk of … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, bonus, due diligence, financial crime, MLRO, money laundering, proceeds of crime, remuneration, risk-based approach, training | Leave a comment

Leak technique

Posted on May 27, 2020 by Susan Grossey author

I’ve been doing some remote training recently for a new MLRO, which has been great fun: we’ve covered all the essential and then plenty of those fun, tangential topics that concern MLROs – including beneficial ownership and (our topic for … Continue reading →