After all the excitement with the Bribery Act, I’m feeling a bit flat. I remember when we were waiting for the Money Laundering Regulations 2007 to come into force, and I spent hours learning how to upload a countdown clock to my website, just for the satisfaction of seeing the days, hours and then – yes, I was this sad – minutes tick away until the great moment. That was nearly four years ago now, and I’m in the mood for some new Regs. Sadly, I know they are at least three years away as we haven’t even had a draft Fourth EU Money Laundering Directive, from which the Regs will spring.
So why do I want to create all this work for myself? Well, I like a challenge. As a non-lawyer, I like to stretch my brain by reading new legislation and spotting the areas of concern and debate. And I worry that a lack of new legislation makes money laundering seem like yesterday’s news, which we all know that it is not – indeed, the launderers would love us to think that it is a solved problem. Finally, I think that we need new legislation to deal with new issues. When the 2007 Regs came in, mobile banking and e-money were in their infancy, while stored-value cards were what you gave your mum for Christmas, and sanctions were updated infrequently. Does this sound like the financial world in which you are now operating? Nope – nor me. We need new Regs, and I’ll even hunt out that old countdown clock to welcome them.
(Incidentally, while I stomping my little trotters in impatience, where is the Corruption Perceptions Index 2011? It used to come out in October, but here we are at the end of November and not a peep. Lots of PEPs, but not a peep. Oh come on – AML jokes are hard.)