No, I’m not talking about our government. When I first started doing AML training, an older and wiser trainer warned me: “When it comes to case studies, your clients will be insatiable, blood-sucking monsters.” In fact, the vast majority of my clients have proved to be absolutely delightful people, generous with the chocolate biscuits and entirely un-monstrous, but he was right about the case studies: they love ’em.
Personally, I’m in two minds about case studies. The ones publicised by agencies such as SOCA and the Egmont Group (is it just me, or does that sound like a great name for a band?) are, by necessity, anonymised. The ones in the FATF reports have all identifying details removed apart from their country of origin. And although these outlines are comforting, in that they provide evidence that money laundering really does happen, for instance, through charities and trust companies, they really don’t give us any more insight than a reasonably imaginative MLRO could guess for himself.
I don’t think clients really want what business schools call case studies – detailed descriptions that take half a day to read and another week to work through. I think they want colourful stories involving their sector that will make staff sit up and take notice, and think, “Wow – that could have been us! I’d better be more vigilant.” So when I am asked to include “case studies”, what I try to do is find relevant stories in the media. I look for human details that will appeal to staff – the little video of Obiang’s fancy cars being hauled off the streets of Paris was pure gold-dust. I look for an underlying crime that will anger people. And I look for a bad outcome for the launderer – rotting in prison, that sort of thing. We’re all quite childlike really: we dignify them with the term “case studies” because we’re grown-ups at work, but actually what we want are some darned good stories. Are you sitting comfortably? Then I’ll begin. Once upon a time there was a very naughty world leader…
I hate money laundering 