Walk on by

The “Today” programme on Radio 4 this morning was full of this story from China.  In short, a toddler was knocked down by a van, and eighteen people walked or cycled past without helping.  Another van then ran over her legs before a passing woman thought to do something.  There is much gnashing of teeth and rending of garments as the Chinese consider whether they have become immune to everything except making money and have lost their sense of decency.  Others suggest that stopping to help is itself a dangerous proposition, as you might be accused of involvement, or sued for administering the wrong first aid, or pilloried for touching a child.

This balancing of risks is familiar to anyone who has ever reported a suspected crime – including staff making internal suspicious activity reports and MLROs making external disclosures.  The concerns are similar, no matter what the crime.  What if I’m wrong and it’s not a crime?  What if I’m right and it is a crime, and because I don’t report it the criminal goes free?  What if the person I report on finds out it’s me and takes revenge?  What if the people I report to think I’m involved?  In short, is it worth the risk and effort?

Of course, from the MLRO’s point of view (and indeed as required by law), staff should always report suspicions of money laundering.  Part of the MLRO’s job is to make that process as simple and comfortable as possible.  Training staff about the reporting procedure, and anticipating and addressing their concerns, is crucial.  Making them angry about money laundering, so that they can’t bear the thought of someone getting away with it, is terrifically helpful.  I don’t expect people to be as incensed about a tax evader or a corrupt politician as they are about a crippled toddler, but half as incensed would be good.

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