We’re all in this together – aren’t we…?

A few days ago I gave a presentation to the Jersey Compliance Officers’ Association (thank you for inviting me) and as I looked around the room, I was delighted to see so many young faces.  I’m not suggesting there’s been a rush on Botox in Jersey: they were actually genuinely young people, making a career in compliance.  (As opposed to in the old days, when you served out the last couple of years of your finance career in the gentle backwater of compliance.)  But this also forced me to realise that I am getting on a bit.  Not that I’m not still gorgeous, of course, but I have been round the AML block a few times -and my pregnant niece has taken to calling me “Great-Aunt Sue”, which does not help, as it brings to mind images of bombazine skirts and reticules smelling of Parma Violets.

So, to my point: what has the wisdom of the years shown me?  Well, I think the most interesting thing I have learnt is that we’re not all in this together.  I used to think that in every jurisdiction there was the triangle of AML co-operation: industry, regulator and FIU.  But I now realise that this is not always a happy little trio.  Sometimes industry and the FIU get along well, while the regulator scares them both to death.  Sometimes the FIU and the regulator gang up on industry.  And sometimes the regulator and industry huddle in the corner whispering about how the FIU just doesn’t understand the world of finance.  It’s a great shame when this happens, as it’s the old “divide and conquer” in action – and the winners are the criminals.  If industry is too scared or ashamed to go to the regulator for guidance, or if the FIU won’t provide reassurance or helpful feedback, or if the regulator is too distant from those it supervises, or if industry wastes its time trying to find ways around the system, so many opportunities for mutual improvement are lost.  As I used to say in my young, idealistic, pre-bombazine days: can’t we all just play nicely together?

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