Your views please: AML for UK NEDs

May I pick your brains, please?  As regular readers will know, I am a writing machine.  I just can’t stop.  Articles, blogs, websites, books, lists – if words are needed on page or screen, I’m there.  I am currently working on a new project, and before I get too far into it I wanted to canvass opinions.

What I am writing is a guide to the AML/CFT regime for non-exec directors of UK firms covered by the ML Regs.  (I have plans, if it works, to adapt it to Guernsey NEDs, Jersey NEDs, etc.)  As I see it, NEDs are expected to sign off on the AML regime of their firm, assessing whether it is indeed appropriate and proportionate, and all too often they are ill-equipped to make such decisions.  MLROs often tell me that getting NEDs to attend training is like herding cats, if those cats had passports and could travel overseas.  And a couple of NEDs have confessed to me that they are embarrassed to admit at this late stage that they don’t really understand what a good AML regime should look like.  So I thought that a slim volume, giving an overview but not delving into the detail that is the province of the MLRO, could answer both needs.  I’m thinking of a print-on-demand paperback, as I’m not sure that NEDs are natural e-book customers.

But that’s just my opinion.  What do you think?  Is there demand?  Would the NEDs in your life buy such a book for a modest emolument?  Should I avoid the word “emolument” in the future?  Comments most earnestly sought.

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11 Responses to Your views please: AML for UK NEDs

  1. Tim Renault says:

    I would have thought that there would be a demand for this as long as it is to the point and not too lengthy (which I am sure you will achieve!)

    Not a huge nember of NEDS in my life at the moment, but from previous lives, I could see a few that would take up the offer.

    As long as the cost is modest, it should do well!

    And definitely avoid using “emolument” in this context in future!!

    Good luck!


  2. Dear Tim
    Many thanks for your comments. I am hoping for succinct and relevant – I’ll go through it with a fine-detail comb. POD paperbacks can be kept to the price of normal ones, so that would be my aim. Emolument-phobia noted.
    Best wishes, and thanks again, from Susan

  3. Pingback: Your views please: AML for UK NEDs | I hate money laundering

  4. Julian says:

    My experience of NEDs is they fall into one of two categories.

    They are either of the ‘can’t get enough training on AML’ or they are of the ‘I’m too busy to be trained’ school of thought.

    I would recommend that you write it so that the MLRO’s that tear their hair out can at least send the errant directors the link to you e-book on demand

    • Dear Julian
      That’s been exactly my experience, so I’m glad to know that someone at the coal-face is finding the same. I have completed a first (very rough draft) and have made a tentative enquiry with the Institute of Directors, to see whether they would be interested in sponsoring or publishing or selling it. As you say, if nothing else it would be a resource for frustrated MLROs!
      Best wishes from Susan

  5. Nicholas says:

    I echo the comments above on NEDS, some are really on the ball and others, well just there to collect their Directors fees!! I think it woud be helpful to have an opening section on their responsibilities and perhaps more importantly for them, the penalties for non-compliance.

  6. Dear Nicholas
    An excellent reminder: I had included a section on responsibilities, but nothing on penalties – I’m just too kind! I shall crack open the thumb-screws immediately. Thank you for the suggestion.
    Best wishes from Susan

  7. Graham Thomas says:

    Hi Susan
    I think the previous responses have got this spot on. In my experience, NEDs would want something fairly brief to firstly explain why a certain topic should be of interest to them and then the kinds of things they might consider to fulfil their responsibilities. You can also point out other sources of information / reference for those NEDs that want to take their knowledge that bit further.

  8. Hi Graham
    That’s another excellent idea – a section on “Where to get more details…”. I will add it right now – and claim all the glory! Still waiting to hear whether the IoD is interested, otherwise I will go it alone – I think time is of the essence, with the current focus on corporate governance, dominant directors, etc. Thanks as ever for your v helpful input.
    Best wishes from Susan

  9. Pingback: Eds and NEDs | I hate money laundering

  10. Pingback: Hoist by my own petard | I hate money laundering

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