Our recent experience of snow has taught me a couple of things: that tabby cats can disappear entirely if the snow is more than six inches deep, and that snow coming over the top of a boot is a most unpleasant sensation. It has also made me reflect – prompted in part by the unedifying squabble between (as the reporters soon started calling them) Mr Heathrow and Mr Gatwick about whose airport was better at dealing with (gasp!) snow in winter – that we are all sometimes guilty of ignoring risks entirely, simply because they are quite small. Granted, London’s airports are rarely troubled by the huge snowdrifts tackled annually by their cousins in Scandinavia – but snow is not unknown in England in winter, and so perhaps more contingency planning should be done.
Those tasked with preventing and forestalling money laundering may have derived false comfort from the ubiquitous risk-based approach – but nowhere does this approach suggest that any risks are so small that they can be ignored. Yes, you are encouraged to rank the risks, and then spend more time on mitigating the more serious and the more likely and the more potentially damaging – much as I should imagine Mr Heathrow spends quite a bit of time on securing his airport against terrorist attacks and plane crashes. But this does not mean that just because a risk is small or rare, you can discount it entirely. I am not advocating overkill; it would be daft for Mr Gatwick to worry for too long about the risk of a shop on his concourse spontaneously bursting into flames, or a cargo of poisonous snakes getting free, but I am sure that somewhere in his manual is a chapter on terminal fires and another on live cargo risks. And likewise, just because you know that it is highly unlikely that your most prized client is in fact a front-man for the Mafia, it does not excuse you from having in place a plan of action should that prove to be the case. And in case you’re wondering, I’ll take snowdrifts over snakes any day.