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.