Thinking the unthinkable

I stayed with a friend this weekend, and her new chap asked me what I do for a living.  I gave the usual potted explanation: I provide anti-money laundering training and advice, so I help institutions to guard against criminal money.  But he, being something of a thinker, did not let it go at that.  “Do they want that, the institutions?” he asked.  “Or is it just because they are required to?”  Gulp.  Help self to large piece of cake for fortification.  But he did raise a good point.

I’m not naive enough to think that banks, law firms, casinos and the rest would spend as much on AML as they do at the moment if the AML legislation were suddenly repealed.  Even with it on the statute books, AML is a hard sell.  But what really got me thinking was: should we actually have AML legislation at all?  (By AML legislation, I don’t mean the primary offences – that’s ML legislation.  AML is regulations and the like, geared to preventing and forestalling.)  After all, we don’t have anti-embezzlement regulations, requiring firms to put in place anti-embezzlement procedures and training, even though the general opinion is that embezzlement is a bit naughty.  But hold on a sec: I’m talking myself round here.  Rather than having anti-embezzlement procedures, and anti-tax-evasion procedures and so on, wouldn’t it be simpler to require institutions to put in place procedures to spot and report the proceeds of any crime?  It’s a catch-all, really: if it’s illegal, you can’t move the proceeds.  What a marvellous idea!  AML, QED.  I only wish I’d thought of it over the chocolate cake.

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4 Responses to Thinking the unthinkable

  1. Roy McCarthy says:

    Susan, that would be like relying on your goalkeeper as your only line of defence. Present regulations provide for defending from the front (initial CDD), wrapping up the midfield (risk assessment), a strong back four (enhanced monitoring) as well as the goalie, who you hope won’t be tested very often.
    Right, back to the Euros…

  2. Roy, this is a perfect analogy. But in your scenario, who are the WAGs? And once you’ve finished with the Euros, don’t forget peace in the Middle East, oh, and the Cleggeron coalition.
    Best wishes from Susan

  3. Some bankers are really honest… During my divorce proceedings I went to see a Scandinavian bank, where a friend of mine was working. Of course, when you know someone in Monte Carlo, they all want to see if they can get that business! When I explained him what my ex did, he said: well, perhaps we better not talk to him. We don’t like this kind of people to be our clients… That felt really nice. But as I have told you before, those money launderers only need 1 bank who will help them out. And unfortunately, there are lots of people who are greedy and have no scruples.

  4. In all fairness, the hugely vast majority of people working in financial services are as honest as the day is long and – more than that – hate the fact that criminals try to abuse their businesses for laundering. But, as you say, it takes only one crooked individual – and word quickly spreads in the criminal fraternity about financial institutions with weak controls, or corruptible staff, or the famous “blind eye”.
    Best wishes from Susan

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