As I mentioned in my last post (isn’t that a tune?), I spent Friday 15 March hobnobbing with the great and the good of the AML world in Brussels. Yes, darlings, I was walking the corridors of power at the EU. Actually, to be precise, I was riding the escalators in one of their many buildings – but I was very over-excited by it all. What to wear? (A 1960s wool dress in a graphic print of pink, purple and cream, so that people would remember me amongst all the serious black.) Where to sit? (Third row from the front, aisle seat.) It was just as you see it on telly: semi-circular rows of seats, head-phones for simultaneous translation, blue circles with yellow stars absolutely everywhere – including on the notepaper, some of which I have brought home to leave on my desk as a swank. Now that I have set the scene, I suppose I should tell you a bit about what I heard. There was a lot said, by over a dozen speakers (including two Commissioners, which we were told several times was Quite An Honour), so I shall do several blogs this week about it.
But what I must say first of all is that – wait for it – I have touched greatness. Yes: I shook the hand of John Carlson, Principal Administrator at the FATF Secretariat. And I’m not being sarky; for me, it was a real thrill to meet the man who puts his paw-mark on the revised Recommendations, the new methodology, the lists of naughty countries and more. And so that I didn’t descend into the depths I have experienced before when meeting heroes*, I prepared a couple of questions to make me sound sensible rather than stalking. In the morning break, I asked about the extension of the definition of PEPs to cover the domestic variety, and on behalf of my beloved small jurisdictions who may be thinking of adopting the new FATF standard on this, I asked whether it would be acceptable – for domestic PEPs – to limit that definition to the PEPs themselves and not include their families and close associates. I explained that in some jurisdictions, the wider definition would haul in everyone on the island. And he said that in his view it should be possible to risk assess domestic PEPs, and – as long as they are spotted as being PEPs and the rationale behind your decision is then recorded – not to then apply EDD to them.
Flushed with success, and wanting to give him the opportunity to remember me and my dress, I collared Mr Carlson again at the end of the conference, and hit him with my second question. Why, I wondered, does the definition of high value dealers mention only trading in goods for cash, and not services for cash – when the risk is not what they are buying, but the cash that they are using. As examples, I suggested people paying school fees in cash (and schools being entirely unaware of the dangers, with not being in the AML family), and criminals disguising money movements as payments to consultants. And do you know what he said? “Because we’ve never thought of it.” I can’t believe that’s true, and will put it down to the poor man being tired at the end of the week, but wouldn’t it be fun if I had thought of something new? So I said that I would expect to see it in the next revision of the Recommendations – cheeky! – and if it does appear, I at least shall be referring to it as the Grossey Clause.
* About a decade ago, I saw Stephen Roche (retired Irish cycling superstar) at a race in London. I finally fought my way through the crowds to meet him, and all I could manage was, “Mr Roche, I’m a really, really big fan”. I may have simpered. And I do know that my normally tolerant husband pretended not to know me for at least an hour afterwards.