I have a confession: I love writing AML manuals. I know, I know – it’s akin to saying that for Sunday lunch I enjoy a nice roast kitten with puppy gravy, but there it is. Who knows when it started, but I have always relished gathering information, sorting it into a logical order, and then determining the best way in which to communicate it. Add my Favourite Subject Ever, and I’m in clover. Rather marvellously, clients do occasionally ask me to redraft their AML manuals; they raise the subject almost apologetically, but I’ve got Word open and a skeleton table of contents in place before they’ve hung up. But, dear readers, I do see some shockers.
The worst – and most common – mistake that MLROs make with their AML manuals is taking shortcuts. When something changes, they make the minimum number of edits that they think they can get away with – which means, invariably, that bits are missed. I know it sounds dull (actually, it doesn’t – but that’s my problem and not yours) but when you change any part of a document you must re-read the whole thing to make sure it still works. Every single page. Otherwise contradictions and omissions will creep in (can an omission creep in, or does it slink out?).
Another regular bugbear is inconsistency. You call it KYC in one chapter and CDD in another. They’re “high risk clients” in this table and “High-Risk Customers” in that one. It sounds nit-picking (and what’s wrong with that?) but inconsistencies will lead to uncertainty and misinterpretation. It’s worth remembering that very few of your staff, no matter what they tell you to the contrary when they sign their form, will read the AML manual from cover to cover. They will turn to it in extremis, when they need to find reliable and unambiguous information quickly.
And tied to inconsistency is style. I love a good, wide, illuminating, fascinating range of adjectives as much as the next person. But the AML manual is not the place to practise your Booker-worthy prose. Keep it clear. Keep it repetitive. If you mean “certified copies of all CDD documents must be obtained and kept on the client file”, don’t say, in the next chapter, “obtain certified copies of the documents” – just repeat exactly the same phrase to make it clear that the standard is unchanging. Keep it clear. Keep it repetitive.
It’s been attributed to almost everyone, from Thomas Hood to Nathaniel Hawthorne, Lord Byron and Maya Angelou, but the maxim remains true: easy reading comes from hard writing. And it’s the responsibility of the MLRO to make sure that the AML manual is very easy reading.