A shiny coat and a wet nose

I’ve been wondering about this for a while: what makes a good MLRO?  No doubt you have guessed by now that MLROs are among my Very Favourite People (up there with policemen working as financial investigators, Lucy Worsley, Jeremy Paxman, Sarah Millican and Donny Osmond – yes, my tastes are catholic).  I love working with MLROs: talking to them, trying to help them, designing training with and for them, writing articles and blog posts for them – they are in my mind constantly.  And over the years, I have met hundreds of them – of all shapes and sizes, both genders and many nationalities.  I have met shiny new ones and tarnished experienced ones, happy supported ones and miserable isolated ones, confident ones and terrified ones (and ones that ricochet from confidence to terror on a regular basis).  But if I were looking to recruit an MLRO, what would I want?

First up, I would want dedication to the AML cause.  The AML requirements – no matter what the jurisdiction – are never clear-cut, and for someone to spend their working day trying to make commercial, moral and legal sense of them, they have to believe that it is all worthwhile.  I’ve been lucky, in that the MLROs I meet tend to be self-selecting, but when on occasion I have met an MLRO who is just box-ticking, it is dismal and depressing.

Secondly, I would want “my” MLRO to be curious: curious about what the legislation actually means and how it can be applied, curious about criminals and what they are doing, curious about how the due diligence steps we take can be leveraged to have the greatest AML impact – always questioning and always learning.

Thirdly, “my” MLRO needs to be morally robust.  I have always thought that, if I were a criminal, one of my first purchases would be an MLRO – who better to have on your side? – and so MLROs need to be as incorruptible as possible.  And – less dramatically but perhaps more commonly – they need to have the moral strength to stand up to the resistance they will almost inevitably encounter in their colleagues: resistance to AML in general, resistance to training, resistance to due diligence, resistance to reporting…

Fourthly, the ideal MLRO needs to be approachable and empathetic – to be the reliable and knowledgeable AML person for all of those colleagues.

And lastly, the ideal MLRO should be able to keep things in perspective: to laugh at the ridiculous, to concentrate more energy on the important issues (I know: let’s call it the risk-based approach), to remember why we are doing all of this, and of course to take pleasure in small victories (only two people off sick on AML training day – woo-hoo!).  Shiny coat and wet nose optional.

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