Quite properly, clients sometimes ask me what qualifications I have to do my AML work. If they mean paper qualifications, the answer is none. I actually trained as a schoolteacher – which I would recommend to anyone, as it teaches public speaking, organisational skills, diplomacy, crowd control techniques and good humour. And after that, nothing is ever quite as scary as trying to get fourteen-year old boys interested in “Romeo and Juliet” – not even telling account managers that yes, all potential clients must have CDD checks done before you can take their money – even the really, really profitable ones.
When I started out in AML, my amateur status was the norm, but things have changed and now we have qualifications designed specifically for the MLRO and others with an AML interest – the two main providers being ACAMS in the US and the ICA in England. I have considered whether I should take one of their courses myself, but I just can’t justify the time and expense when no-one is demanding that I be so qualified.
As for MLROs, at the moment they are required to be fit and proper and generally tip-top people, but I don’t think it’s too outlandish to suggest that the time may well come when they will be expected to show paper proof of their suitability for the role. This of course will open up a new can of worms: who will be the approved providers of such qualifications, and who will monitor and moderate their work?