This week I have been telling you all about my visit to Brussels last week, and my excited attendance at an EU conference on AML/CFT and especially MLD4 (the Fourth Money Laundering Directive). As at any such gathering, the speakers varied considerably – although, given their elevated professional status, most were very good. One of the best structured speeches was given by Juan Manuel Vega Serrano, from the Spanish Ministry of the Economy and Competitiveness. He spoke in lovely musical Spanish, and so I suppose the praise for the flowing nature of what he said actually belongs to the translator – although when it was time for questions, Señor Vega Serrano spoke in faultless English. Puts me to shame.
He made the point that when it was first drawn up, AML legislation was designed for specific professionals – mainly bankers, who have come (with varying degrees of acceptance) to see it as “a reasonable, proportionate cost of doing business”. However, with first MLD3 and now MLD4, “we have seen the expansion both of predicate offences and obliged entities – and we need to explain to people why we are expanding like this. We are moving from a very regulated field (of businesses used to regulation, and with experienced supervisory bodies) to businesses without this regulatory and supervisory tradition. We need to explain to such entities that this is not just a whim – that we are trying to pick up on and solve serious societal issues.” Being hot on education myself (I always maintain that it is easier to get people to do something if they understand why it needs doing) I was very impressed by Señor Vega Serrano’s approach.
Quite fittingly, given that the conference was taking place on Cheltenham Gold Cup Day, during the coffee break I managed to shoehorn myself into a group of gentlemen from the English bookmaking industry – one of those new “obliged entities” referred to by Señor Vega Serrano. Knowing little about the mechanics of bookmaking myself (beyond delivering betting slips on behalf of my great-uncle when I was six, so that he could keep technically the promise he made to his wife not to place any more bets himself….) I was delighted to be offered an invitation to go to the head office of one such company and learn all about it. Will I be going? You bet!