Avuncular oversight

First, a point of grammar: the English language has one of the largest vocabularies in the world, and yet there is no female equivalent of the word “avuncular”.  People have suggested “aunticular”, but that’s a bit ugly, isn’t it?  So we shall stick with avuncular – i.e. characteristic of an uncle, or acting in a kindly manner towards a younger person – although I mean it to apply to MLROs of either gender.  To elaborate: when I am training MLROs on dealing with staff, I advise them to take “an avuncular interest” in the welfare of those staff, specifically as it pertains to their vulnerability to financial crime.  And I can tell from their expressions that for some MLROs this is not a welcome recommendation.

My thinking is this.  We are comfortable with the concepts of CDD and monitoring when they apply to clients.  We like the idea of keeping an eye on clients for changes in their pattern of transactions or other activity, and even try to have regular meetings with them whenever possible so that we can check that they still look alright and don’t exhibit the twitches of a wanted man or the sunken eyes of a tormented one.  All I suggest is that it makes sense to do this with staff as well.  After all, to put yet more mileage on a well-worn phrase, you are giving your staff the keys to the kingdom.  With their access and knowledge, your own staff are much more of a danger to you than any client could be, should they go off the rails (yes, this kingdom has railways – and I can mix metaphors if I want to because it’s my blog).  So I think it makes perfect sense regularly to cast a eye over your staff to look for signs that something is not right – perhaps someone is living beyond their means, or coming in late when they were always punctual, or withdrawing from their colleagues, or showing signs of an addiction.  I think the business books call it “management by walking around”.  I’m not saying that you should stalk your staff: just be friendly, concerned and approachable, so that if they do stumble, they will feel that they can turn to you.  Think Uncle Remus rather than Uncle Junior.

This entry was posted in Due diligence, Money laundering, Supervision and tagged , , , , , , . Bookmark the permalink.

1 Response to Avuncular oversight

  1. Pingback: When good people go bad | I hate money laundering

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