I hear through the grapevine (yes, it’s a long grapevine, even in Tarzan terms) that in recent briefings to industry, a regulator has been saying that there is a dearth of good training for MLROs. In the jurisdiction in question, I run two workshops a year, for sixteen MLROs each time, so I’m reaching only a fraction of the MLROs available for training. How are the rest keeping themselves up-to-date?
We all know that regular staff are the very devil to train when it comes to AML, but I would have thought that MLROs, of all people, would know how fast-changing is this subject. Granted, we haven’t had many amendments to legislation in the past couple of years, but with the FATF’s recently updated Recommendations, and a fourth EU money laundering directive on the horizon, it’s only a matter of time. Perhaps it’s like a mother giving up her own food to nourish her children: with a limited training budget, the caring MLRO focuses on his staff rather than himself. But it’s like they say on the planes: fit your own mask before helping others with theirs. How can the MLRO guide his staff through the ever-moving world of AML/CFT if his own compass has not recently been calibrated? (I’m growing weary of this analogy and rather wish I hadn’t started.) So, MLROs, put yourselves first for a change: you know you’re worth it.
(By the way, the poll on who should join Edward on his next adventure is still open. At the moment, Winston the teddy bear is in the lead – and I know you’re all voting for him just to watch me struggle to write a stuffed animal into the plot. I can do it – just watch me. But in case you feel that there might be someone better, I’ll leave the poll open for a few more days.)