Whenever anyone finds out what I do for a living, they ask, “So, what got you into that line of work, then?”. And I always suspect that my true answer – serendipitous accident, and I stayed with it because I just love it – is a sorry disappointment to them. What they want to hear is that I researched the market, spotted the growth in AML legislation, realised that more AML trainers would be needed, and educated myself to meet this demand. (Which I do know would show me in a more flattering light than the truth. Much like my wedding photos.) But now that I am immersed in AML, and have made peace with never achieving my other ambition (being awarded an honorary double PhD in criminology and English for being just too fabulous), I really should revisit my business plan from time to time to see whether it still has legs. (Or any body part at all – surely you didn’t think for one second that I actually have a real business plan as opposed to some indecipherable notes along the lines of “should I Tweet?” and “customised choc bix for prizes….?”.)
So the big question is: is there still growing demand for AML services, and can I meet some of that demand? I work in only a handful of jurisdictions, but in just those few there are enough legislative changes coming up to keep me busy for a while (Fourth Money Laundering Directive, changes to Guernsey’s AML/CFT regime, new anti-bribery legislation in the Isle of Man – it’s all go, I tell you). With the FATF’s revised evaluation methodology placing so much emphasis on effectiveness, this is bound to filter down to in-house requirements (if the country has to demonstrate effectiveness, then the regulator has to; if the regulator has to, then the regulated have to). And so AML training will have to be shown to be achieving whatever goals were in mind when it was designed – which is an ongoing challenge for both MLROs and AML trainers. Plus, of course, there are always fresh-faced new joiners in the regulated sector, bright-eyed and desperate to hear about the exciting world of AML. So for now, I think I’ll stick with it – or at least until that PhD arrives and I have to go on a world lecture tour.