Double-edged sword. Poisoned chalice. Sting in the tail. Yes, it’s time to talk again about the risk-based approach. With the advent of the RBA (see how chummy we are now, the RBA and I) we welcomed the idea of being able to make our (well, your) own judgements about money laundering risk – to differentiate with simplified and enhanced due diligence, to do more or less frequent monitoring, to turn our backs on the tick-box. But with this new freedom comes extra responsibility: if you are going to make informed decisions, you have to be, well, informed. And not just informed, but well-informed.
As I have said many times before, there is now no shortage of ML and AML information on offer; as I write, my desk is covered with articles, reports, stories and comments gathered over the past weeks. What I lack – and what I suspect many MLROs also lack – is time to read and what my English teacher used to call “inwardly digest” this information. Just reading it is not enough: I need to read it, and then decide whether it is (a) reliable, (b) important, (c) worth sharing, (d) worth reacting to, and/or (e) life-changing. And to make these judgements, I need time and space to think. Stopping to answer the phone or jumping to the ping of an email will make me lose my own train of thought or the thread of someone else’s argument. And I talk as someone who refuses to switch on her ancient mobile phone or even contemplate having a Blackberry, so goodness knows how those of you who are much more connected than I am get the mind space you need to decide on (a) to (e) above. With so much riding on it (think of the penalties for having an inadequate AML regime, underpinned with poor RBA decisions…), just how does today’s MLRO carve out the time and space he needs?