The curious incident

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.

This entry was posted in AML, Due diligence, Money laundering and tagged , , , , , , . Bookmark the permalink.

2 Responses to The curious incident

  1. Graham Thomas says:

    Hi Susan

    That is good advice about the potential need to be able to demonstrate our thinking to people from outside the firm. It can also be worth mentioning the “passage of time” factor. What is nice and clear in our memories today, at the time we form a new business relationship or undertake a particular transaction, is unlikely to be quite so easy to bring to mind if we are asked to account for actions and decisions from several months and / or years previously. I have to confess, I often have trouble remembering things from yesterday, perhaps I should make even more notes !!

    Best wishes


  2. Graham, Graham – now I feel sure that I vaguely remember that name from somewhere….!

    You are absolutely right: what seems unforgettable to us today rarely is, and trying to dredge up what happened years ago is hard enough, let alone why we did it! A very timely reminder in all senses of the word – thank you.

    Best wishes from Susan

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