I’ve been working in Guernsey this week, and they held their election on Wednesday. An election is basically the most public manifestation of the basic human need for feedback; with an election, the politicians find out whether the people think they have been doing a good job or not. (Nicholas Sarkozy take note. In Guernsey, the father of the house lost his seat, while the Chief Minister just scraped in. Ouch.) We all need to know whether what we are doing is – for a start – the right thing. We then like to know whether it is appreciated, or making a difference, or valued – or even noticed. I hand out feedback forms after workshops, so that I can learn how to improve for the next one. (People are pretty sick of feedback forms, so I sweeten the deal by giving a pound to charity for each form returned to me.)
At a workshops for Guernsey MLROs this week, I asked them what they wanted from their FIU and their regulator. “Feedback!” they chorused. Staff need to know from their MLRO that they are spotting and reporting the right things. MLROs need to know from their Board that they are implementing an effective and proportionate AML/CFT regime, and from their FIU that they – like their own staff – are spotting and reporting the right things. FIUs need to know from their law enforcement partners that they are collecting and passing on the right intelligence. And law enforcement agencies need to know from the public that they are pursuing and prosecuting the right crimes. It all takes time and resources, but – as anyone who has ever had any dealings with children knows – it is crucial to the learning and compliance process. We all need to know we’re getting it right – it’s why we bloggers blog (with an implicit plea for comments) rather than simply posting our thoughts on a static website. And it’s certainly an easier way of getting feedback than standing outside a Guernsey polling booth in the wind, rain and hail.