Cast your mind back to the turn of the millennium, and how we chose to mark this amazing milestone. There were regeneration projects, fundraising drives, development initiatives – and the Dome (which defies categorisation). The FATF signalled the passing of another thousand years by launching its black-list, sorry, list of non-co-operative counties and territories, and this NCCT project has since been abandoned in favour of a list of countries with “strategic deficiences” in their AML/CFT provision. Updating this list forms the backbone of every FATF plenary meeting – most recently the one in Paris in mid-October. But trying to keep track of it is a tricky business.
For a start, the list comes in layers: I call them “naughty”, “last chance saloon” and “beyond the pale” – which may explain why I have yet to be asked to attend an FATF meeting of any kind. And jurisdictions move between the layers depending on how much effort they are putting into getting into line with the FATF’s requirements or – conversely – how big a raspberry they blew when asked to make changes. And whenever a new list is published, trying to work out who’s in, who’s out and who’s shaking it all about can be awkward, requiring the use of several coloured highlighters and some big arrows. Which gave me an idea. It works for traffic lights, and it works for fat and sugar content of our food, so couldn’t we use the “red, amber, green” (or RAG) ranking for countries on the list? And then a country can be tagged “green moving up to amber” or “stalled on red” – which personally I find much easier to visualise. Plus it makes for pretty training slides, which I always welcome.