Timing is not only the secret of great comedy – it is also the secret of great AML. There are so many points in the application of AML procedures at which timing is an issue, from the very beginning (when do we do due diligence checks on this client?) to the very end (when can we get rid of their records?). Some timing concerns can be resolved fairly precisely. To the first question, the answer is “before we do anything for them that could, with the benefit of hindsight, lay us open to a charge of money laundering”. And for the second, the law provides a set retention period.
Other questions of timing are far less simple to answer. How long should we give this client to supply the document we have asked for? How long should we allow a member of staff to feel uneasy about a situation before expecting them to realise that they are suspicious and make a report? How long can an account manager be given to perform an annual review of a client file? In jurisdictions with no formalised consent timetable, how long should we wait to hear from the FIU, granting or withholding consent? How long can an MLRO wait for his Board to approve extra expenditure on AML? As with so much in the world of AML, it all comes down to documentation: documenting that you have started the process, and then keeping track of its progress, chasing when necessary, and finally calling a halt at a sensible point. Not unlike marriage, really.
I hate money laundering 