This week, for the last time, I watched “The Apprentice”. What a nasty programme it is. The two teams competed on some daft task – selling gourmet fast-food in Scotland, I think – and were measured by the amount of profit they made. The winning team bounced off for their reward, while the losing team turned to the important business of ripping each other to shreds. “It’s our team leader’s fault – he was hopeless,” said one (despite having earlier said that the leader had done well). The team leader however was of the view that “I believed them when they said they knew all about sales, but they were useless”. Just what is this teaching people about team-work and striving together towards a shared goal? (Mind you, why am I surprised? Wasn’t it Sralan himself who praised the winner of a previous series for telling lies on his CV?)
I was talking to some MLROs not long ago, and they said that it is a pity that due diligence can sometimes become a battlefield, with regulated firms taking one position and regulators another. With the risk-based approach, there is surely an expectation that people’s views of what is appropriate and proportionate will vary – indeed, most guidance makes reference to any risk analysis taking account of the “experience” of the regulated sector. It seems a shame, therefore, that such differences should be labelled “wrong” (except in the most egregious circumstances, when there is clearly a dereliction of duty). Quite apart from the bad feeling that this combative approach creates, it misses the crucial central purpose of it all: aren’t we supposed to be on the side of the angels, working together to defeat the money laundering forces of evil? Please let’s not emulate the model of “The Apprentice”: a group paying lip service to co-operation when it suits them, but then turning on each other as soon as problems are encountered.
I hate money laundering 