Tag Archives: risk

Could do better

Posted on August 25, 2021 by Susan Grossey author

One of my most over-used phrases in my AML training is “new entrants to the AML family” – when I am explaining that we cannot expect all sectors (e.g. estate agents, art market participants) to be as au fait with … Continue reading →

Posted in Uncategorized | Tagged AML, business risk assessment, CDD, FCA, Financial Conduct Authority, MLRO, PEPs, Regulations, reporting, risk, SARs, suspicion, training | Leave a comment

The young and the riskless

Posted on March 24, 2021 by Susan Grossey author

I never thought I’d say this, but there are two great advantages to being 55: (a) I’ve had my first covid jab (one shivery night afterwards but apart from that – woohoo!), and (b) I’m not being targeted quite as … Continue reading →

Posted in Uncategorized | Tagged FCA, Financial Conduct Authority, fraud, fraudster, investment, MLRO, money laundering, research, risk | Leave a comment

More Bloody Embezzlement?

Posted on March 4, 2020 by Susan Grossey author

Just like police officers, customs officers and passport officers, MLROs find themselves doing a certain amount of profiling when it comes to looking for high risk clients. We know about certain high risk occupations and high risk nationalities and even … Continue reading →

Posted in Bribery and corruption, Money laundering, White collar crime | Tagged AML, charities, due diligence, financial crime, money laundering, proceeds of crime, risk, risk assessment, suspicion, white collar crime | 4 Comments

Made to measure

Posted on August 17, 2018 by Susan Grossey author

About once a year I will say in a dreamy voice, “Perhaps I should do a PhD in criminology…”. I love the idea of spending months in the library as I craft my thesis, and then becoming the first-ever Dr … Continue reading →

Posted in AML, Money laundering, Publications | Tagged AML, communication, due diligence, Financial Conduct Authority, financial crime, legislation, money laundering, publications, research, risk, risk appetite, white collar crime | 6 Comments

Training across the Board

Posted on December 18, 2017 by Susan Grossey author

At the end of each year I do a review of what I have done during that year. Each time I issue an invoice I categorise it by jurisdiction, by sector and by activity type, and this enables me to … Continue reading →

Posted in AML, Regulation, Training | Tagged AML, corporate governance, GFSC, governance, Guernsey, Guernsey Financial Services Commission, money laundering, risk, training | 4 Comments

Near-o tolerance

Posted on July 14, 2017 by Susan Grossey author

A recent article in the Economist made a very valid point about recent AML endeavours – that sometimes they can have unfortunate consequences. I have blogged quite a bit about “de-risking”, or what the FATF calls “the wholesale cutting loose … Continue reading →

Posted in AML, Money laundering | Tagged AML, de-risking, due diligence, financial crime, government, money laundering, proceeds of crime, risk, risk-based approach | 7 Comments

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 →

Posted in AML, Money laundering | Tagged AML, Financial Action Task Force, financial crime, government, money laundering, National Risk Assessment, publications, risk | 3 Comments

The risk of compassion

Posted on September 15, 2015 by Susan Grossey author

I have just finished reading a book called “A Long Walk Home”, which is an account by Englishwoman Judith Tebbutt of her ordeal of being kidnapped by Somali pirates who killed her husband and then held her at various locations … Continue reading →

Posted in AML, Due diligence | Tagged financial crime, money laundering, Money Laundering Regulations, organised crime, risk, risk-based approach, white collar crime | 1 Comment

An ugly new word: de-risking

Posted on August 26, 2014 by Susan Grossey author

Over the past few years, we in AML have grown used to new terms. We’ve learnt to leave behind KYC, and concentrate instead on CDD, to replace STRs with SARs. While taking on board the risk-based approach (another new term), … Continue reading →

Posted in AML, Due diligence | Tagged AML, due diligence, equivalence, FATF, government, MLRO, money laundering, PEP, risk, risk-based approach | 3 Comments

Coming thick and fast

Posted on October 8, 2012 by Susan Grossey author

Double-edged sword. Poisoned chalice. Sting in the tail. Yes, it’s time to talk again about the risk-based approach. With the advent of the RBA (see how chummy we are now, the RBA and I) we welcomed the idea of being … Continue reading →