Tag Archives: Transparency International

Boxed into a corner

Posted on October 6, 2021 by Susan Grossey author

What else could I write about this week except the Pandora Papers? The initial focus will be on the individuals named in the leak, but away from the gory headlines will be the real work: looking at the enablers. The … Continue reading →

Posted in Uncategorized | Tagged AML, beneficial ownership, ICIJ, International Consortium of Investigative Journalists, money laundering, Panama Papers, Pandora Papers, Paradise Papers, professional enabler, Tax, Tax Justice Network, Transparency International | 2 Comments

Calling a spade an earth spoon

Posted on May 5, 2021 by Susan Grossey author

If you’re a fan of the current UK government – and particularly the Eton mess whose name shall not be spoken – I suggest you stop reading now. For my part, I consider them a corrupt regime equal to that … Continue reading →

Posted in Uncategorized | Tagged AML, corruption, Good Law Project, government, kleptocracy, money laundering, tax evasion, Transparency International | 2 Comments

Back to school

Posted on February 24, 2021 by Susan Grossey author

When I was eleven I spent four terms in a girls’ boarding school in Worcestershire – as an only child I did not take well to the lack of privacy, and by far my fondest memory is of a day … Continue reading →

Posted in Uncategorized | Tagged AML, bribery, CDD, corruption, money laundering, monitoring, National Crime Agency, NCA, OCCRP, PEP, Russian Laundromat, Transparency International | 6 Comments

Take my word for it

Posted on December 18, 2019 by Susan Grossey author

I have written before about the reliance dilemma – the fact that nearly everyone’s AML legislation and guidance says that although you can delegate some or all of your AML work, you cannot delegate the responsibility for that work being … Continue reading →

Posted in AML, Due diligence, Money laundering | Tagged AML, corporate service provider, due diligence, equivalence, financial crime, government, legislation, ML Regulations, MLRO, money laundering, reliance, research, risk-based approach, Transparency International | 1 Comment

Adding some blacking to the UK pot

Posted on February 6, 2019 by Susan Grossey author

Any crime that generates money can lead to money laundering, but one of the biggies – and one of the most worrying for governments, with its reputational implications – is corruption. We tend of think of high-level, regime-toppling corruption (naming … Continue reading →

Posted in AML, Bribery and corruption, Money laundering | Tagged AML, bribery, corruption, Corruption Perceptions Index, due diligence, financial crime, government, money laundering, proceeds of crime, publications, research, Transparency International | 2 Comments

Money launder-bling

Posted on September 19, 2018 by Susan Grossey author

Working in Guernsey this week, I was talking to a client about the concept of the High Value Dealer (under local legislation, those who “[trade] in goods where there is received… a payment or payments in cash of at least … Continue reading →

Posted in AML, Money laundering | Tagged AML, due diligence, financial crime, High Value Dealer, HVD, money laundering, National Crime Agency, NCA, proceeds of crime, SARs, Transparency International | Leave a comment

Don’t look – but must look

Posted on February 4, 2016 by Susan Grossey author

I’m going to state my position from the outset, so that if you don’t agree you can get your snarls over and done with now, rather than building up a head of steam and perhaps doing yourself a mischief. I … Continue reading →

Posted in AML, Due diligence | Tagged AML, communication, due diligence, financial crime, government, legislation, publications, research, Transparency International | 1 Comment

Tales of the unexplained

Posted on June 15, 2015 by Susan Grossey author

“When did you stop beating your wife?” Famous as the question to which there is no right answer, this is now joined by “Don’t you support civil liberties?”. Of course we all agree that there should be civil liberties, but … Continue reading →

Posted in Bribery and corruption, Money laundering | Tagged asset forfeiture, corruption, financial crime, forfeiture, legislation, money laundering, PEP, proceeds of crime, suspicion, Transparency International | 4 Comments

Wonky perceptions of risk

Posted on April 7, 2015 by Susan Grossey author

I’ve been mulling, as you do, and I’m a bit concerned about the Corruption Perceptions Index published annually by Transparency International. It is a fine index, to be sure, and one I consult regularly myself, but it’s not the answer … Continue reading →

Posted in AML, Bribery and corruption, Due diligence | Tagged AML, corruption, due diligence, FCA, Financial Conduct Authority, money laundering, research, Transparency International | 2 Comments

Happy Democracy Day!

Posted on January 20, 2015 by Susan Grossey author

Today in the UK is Democracy Day, marking the 750th anniversary of the first parliament of elected representatives at Westminster, the de Montfort Parliament. (In homage to my readers in the Isle of Man, I should point out that we … Continue reading →