We all have our dreams, don’t we? Perhaps some of you long to sail around the world, or play golf at Augusta, or win “Strictly Come Dancing”. If so, you’re all much more interesting and rounded than I am – because my dream is to serve on a governmental AML committee. The UK used to have – indeed, may still have, but if so it is preserved in aspic – a Money Laundering Advisory Committee, and I pestered these people shamelessly. I offered to do free research, I offered to make tea (which they wisely declined – my tea is shocking), I offered to serve in any dogsbody-like capacity at all, but no go. I still long to do this, and so I leap at the next best thing: consultations.
Thankfully, as AML is quite a Hot Topic, there are plenty of consultations around. The FATF had a biggie on the 40 Recs not long ago, and the Council of Europe then had a follow-up consultation on the FATF’s findings from their consultation. The Guernsey Financial Services Commission is currently looking at their own AML regime, and I managed to sweet-talk them into letting me respond to what I imagine was originally intended as a domestic consultation for Guernsey folk. I just love consultations: I print out the relevant bits, I attack them with my highlighter pen (and, I am afraid, my Lynne Truss-like grammar detector), I go for a bike ride to mull over critical points (seriously: pedalling is perfect for mulling), and then I send in a carefully crafted response. For both the Council of Europe and the GFSC, I was their first respondent – which surprised the Council a lot, the GFSC rather less (as they know me and my obsession) and me not at all. As you may have guessed, I am never short of an opinion on AML.