Tag Archives: terrorist financing

A welcome divorce

Posted on December 15, 2021 by Susan Grossey author

A significant change was made to my AML-ish life on 26 October 2005: on that date appeared the Third Money Laundering Directive, with the addition of “and terrorist financing” to its title, whereas First and Second had been pure money … Continue reading →

Posted in Uncategorized | Tagged AML, AML/CFT, business risk assessment, CFT, financial crime, money laundering, money service business, National Risk Assessment, terrorist financing, Third Money Laundering Directive, training | 2 Comments

Save our SARs

Posted on October 28, 2020 by Susan Grossey author

I am a fan of the philosophy of SARs: I think it is correct that businesses handling client money should be obliged to report to the authorities if they suspect that that money is the proceeds of crime or connected … Continue reading →

Posted in Uncategorized | Tagged AML, banking, Hong Kong, investigation, legislation, money laundering, National Crime Agency, NCA, reporting, SARs, suspicious activity report, terrorist financing | 2 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

Maman’s the word

Posted on October 23, 2017 by Susan Grossey author

I know that AML and CFT go together. I’m not convinced that they belong together, but I am swimming against the tide, which seems to favour putting all financial crime into the same category. And so I am careful to … Continue reading →

Posted in Due diligence, Terrorist financing | Tagged AML, due diligence, financial crime, MLRO, terrorist financing | 8 Comments

Who’s on the FATF’s naughty step?

Posted on July 1, 2016 by Susan Grossey author

So the FATF’s latest take on their list of naughty countries – or, more properly, those jurisdictions with strategic AML/CFT deficiencies – is out. Their latest plenary meeting, this time in Busan in Korea, ended on 24 June 2016, and … Continue reading →

Posted in AML, Money laundering | Tagged AML, due diligence, equivalence, FATF, Financial Action Task Force, money laundering, proceeds of crime, terrorist financing | Leave a comment

Lifelong learning

Posted on April 27, 2015 by Susan Grossey author

One of the benefits of the AML/CFT mutual evaluation regime is its reiterative nature – the fact that countries are visited, given a report with suggestions for improvement, and then revisited. Between visits, governments submit progress reports to keep the … Continue reading →

Posted in AML, Money laundering, Publications | Tagged AML, communication, due diligence, FATF, Financial Action Task Force, financial crime, money laundering, publications, terrorist financing | 2 Comments

The path paved with bad intentions

Posted on June 10, 2013 by Susan Grossey author

Last week it was announced that Florindo Flores – better known as Comrade Artemio, the last original leader of the Peruvian communist party (Sendero Luminoso, or Shining Path) – had been sentenced by a court in Lima to life in … Continue reading →

Posted in Money laundering, Organised crime, Terrorist financing | Tagged corruption, financial crime, government, money laundering, organised crime, proceeds of crime, terrorism, terrorist financing | Leave a comment

Clandestine legislation

Posted on May 3, 2013 by Susan Grossey author

There I was on Thursday morning, my whole day carefully planned ahead of me (including two McVitie’s dark chocolate digestives at elevenses – something to aim for), when wham! I opened a news feed and there, nestled unobtrusively in its … Continue reading →

Posted in Legislation, Money laundering | Tagged AML, due diligence, financial crime, government, Isle of Man, legislation, money laundering, non-executive directors, proceeds of crime, terrorist financing, writing | Leave a comment

Fowl play

Posted on March 4, 2013 by Susan Grossey author

What do you call a turkey that steps back from the precipice? A wise old bird, that’s what. Long story short, at the October 2012 meeting of the Financial Action Task Force, a statement was issued about Turkey and its … Continue reading →