Now you and I know that record-keeping is not the most thrilling part of AML. (What is? Well, I’m jolly keen on training, and I also like the challenges around sanctions, PEPs, EDD and high-risk clients. Thank you for asking.) But we have to recognise that dull old record-keeping is really, really important. As poor Mr Wigley found out when he sweated through four days on the stand in court, talking about one wretched SAR, it is crucial that you have on record not only who did what and when (which is the easy bit in record-keeping terms), but also why. If you will permit me an analogy (I love a good analogy to start the week), it’s like those dot-to-dot puzzles we all did as children: who, when and what are the dots, but it is only with the drawing in of the why lines that the picture becomes clear.
Ironically (oo, irony as well as an analogy – I’m spoiling you today), it is often the why that is not noted down, and always the why that is hardest to recall. It might take some time, but you can usually unearth who did something and when they did it – in our modern world of constant communication, there will nearly always be a record of these basic facts. But as for their reasoning behind their action, well, once that’s gone, it’s gone. If I asked you why you chose the sole rather than the steak for that dinner six years ago, you know, the one in that restaurant in that city – could you tell me? You might just dredge up a memory of the restaurant and the city, but why you favoured one menu item over another? I doubt it.
So this is why record-keeping needs a revamp. It’s not just collecting bits of paper (or scans thereof) and stuffing them into a file. It’s thinking about why you are doing this (why those bits of paper and not others? why only once every three years and not annually? why accept this client or this transaction at all?) and then recording your decision-making process. The word “because” (or, if you’re feeling posh, “therefore”) should appear a lot. If Frankie Avalon, Fleetwood Mac, Bronski Beat, Carly Simon, Annie Lennox, Mary J Blige and countless others can write whole songs asking “Why”, it must be a good question.