Good cop, bad cop, cr*p cop

At least once a quarter, someone in a training session somewhere will ask: “What if I think the MLRO is crooked?  Who should I report to then?”  Of course I explain that legislation always allows for reporting direct to the FIU, and that the MLRO is provided as an in-house convenience to save you having to go elsewhere – rather like a coffee machine.  Perhaps one of those slick machines that comes with George Clooney leaning up against it, black bowtie loosened…

Back in the real world, it is a very good question – and certainly not beyond the bounds of possibility.  Personally, if I were a money launderer, I would spend a good whack of dough buying an MLRO, thus ensuring that no staff suspicions about anything I did would ever get out to the FIU.  So what would you suggest?  What would you do if you suspected that your MLRO was a bit dodgy?  Drop a hint to the regulator?  Report to the FIU, or to the ordinary police?

To be fair, it’s probably quite clear cut if you suspect him of colluding with criminals – dob him in and get first dibs on his parking space.  But what if he’s just a bit useless at his job?  What if you fear that he is not analysing internal reports properly, or doesn’t have a handle on current risks and vulnerabilities, or can’t stand up to the Board when it comes to difficult “compliance vs commerce” decisions?  Naming no names, I did once meet an MLRO who couldn’t do the job for toffee, and I had a quiet word in his regulator’s shell-like.  But it took me about a week’s deliberation and dithering to decide to do that – what would you have done?

This entry was posted in AML, Due diligence, Money laundering and tagged , , , , . Bookmark the permalink.

2 Responses to Good cop, bad cop, cr*p cop

  1. Claire says:

    George Clooney would just make my knees shake. I’d probably be his money laundering aide. But seriously, it is not easy to be taken serious when you accuse someone in a position of confidence. It once happened to me, when I was 23. I started as a sales manager at an office supply center. And one day the new office manager was introduced. He was a crook I had met a few months earlier, and that after reporting to the police (following the advice of a TV personality my boss was working with and who was being stalked by the man), I was taken on a stake out with them. (Yes, my life has some exciting stories) Of course, my new boss did not take me serious. But they were kind enough to hide my personal file, for which he was looking immediately! I quit my job. But I am happy to say that months later the man got caught for trafficking office material from the warehouse. Told you so, should have listened to the dumb blonde! 😀

  2. I know one MLRO who was eventually bullied out of her job because the Board would not allow her to disclose on a very favoured client. Thankfully this is rare, but what a difficult position for her. And it would be a very foolish person indeed who would consider you a dumb blonde, Claire!
    Best wishes from Susan

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