Tag Archives: source of funds

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

The woes of UWOs

Posted on April 21, 2021 by Susan Grossey author

Unexplained Wealth Orders are now three years old. Although many would like to see their reach expanded – divorce lawyers are particularly interested – they remain available only in cases involving PEPs or those suspected of serious criminality. And indeed, … Continue reading →

Posted in Uncategorized | Tagged AML, CDD, Criminal Finances Act 2017, Mansoor Mahmood Hussain, MLRO, money laundering, National Crime Agency, NCA, source of funds, source of wealth, suspicion, Unexplained Wealth Order, UWO, Zamira Hajiyeva | 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

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

Wimples and wagers

Posted on December 21, 2018 by Susan Grossey author

In recent AML training I have found myself talking more and more about the “CDD jigsaw”. As with all jigsaws, the CDD version involves gathering lots of little bits of information – some of which might seem indecipherable or unrelated … Continue reading →

Posted in AML, Money laundering | Tagged AML, casino, due diligence, financial crime, Gambling Commission, money laundering, proceeds of crime, source of funds, suspicion | 2 Comments

The devil in the detail

Posted on October 8, 2018 by Susan Grossey author

I had an interesting phone call with a compliance officer the other day – she will recognise herself in this description. We were talking about a possible suspicion, and I was impressed by both her attention to detail and her … Continue reading →

Posted in AML, Money laundering | Tagged AML, compliance, due diligence, financial crime, money laundering, proceeds of crime, source of funds, source of wealth, suspicion | 1 Comment

Source for the goose

Posted on June 1, 2018 by Susan Grossey author

I am about to shut down for a fortnight’s holiday – my next blog post will be on Monday 18 June – but I thought I would like to leave you with a clever idea to mull. No, it’s not … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, corruption, due diligence, financial crime, government, legislation, money laundering, proceeds of crime, source of funds, source of wealth, tax evasion | 4 Comments

Do as I say

Posted on February 20, 2017 by Susan Grossey author

I’m going to do to you what is often done to me: I am going to tell you my own anti AML story. Actually, it’s an anti anti AML story – you’ll see. In deference to the diktats of the … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, due diligence, financial crime, proceeds of crime, source of funds, suspicion | 7 Comments

The test of time

Posted on January 28, 2013 by Susan Grossey author

During some AML training last week, someone asked me a question that I am regularly asked, and – despite this (you’d think I’d learn) – I still don’t have a good answer to it. In short, they wanted to know … Continue reading →