Since writing my post on Monday about the importance of why, I have been thinking a great deal about records – and, more specifically, file notes. These are the bits that explain, that tell the story of why certain decisions were made, and what was discussed and suggested and decided. And we all know that they are the hardest bit to get staff to write. It’s a fairly simple task to design a take-on or monitoring form – a template that they have to follow, with boxes to tick and options to select and specified documents to seek out and attach. But say to them something woolly like, “Remember to update your file notes” – and they will generally decide that it’s just much easier not to.
So how to persuade them? Well, I think it’s always worth reminding them that if the wheels come off and there is a money laundering enquiry or investigation, the people doing the enquiring and investigating will not be members of your own firm, versed in its ways and party to its decision-making processes/foibles. Rather, they will be outsiders – regulator-flavoured outsiders, or FIU-flavoured ones, or police-flavoured ones. And as outsiders (and ones who have to maintain their objectivity), they will have to rely on the information before their eyes: they can believe only what they see written down. And if nothing is written down, they will draw their own inferences and conclusions, which may well not be to your advantage. As Christopher observes in Mark Haddon’s novel “The Curious Incident of the Dog in the Night-Time”, the odd thing is not what did happen, but what did not happen – the dog did not bark. Likewise, investigators may decide that the most disturbing thing of all is not what was written down, but what was not – so let’s encourage those account managers to bark.