Earlier this week I was running a workshop for people who are responsible for AML training within their firms, and we had a familiar debate: face-to-face or CBT? (There are other options, but those are the two main ones: you either train your staff with a person or with a computer.) I make my living from face-to-face training, so naturally I am going to sing the praises of that particular option, but in an ideal world, I think most people would agree with me that the very best way to teach someone about AML – or indeed about anything – is to have a human being explain it to them in person. But we do not live in an ideal world: we live in a world where people are too busy to take time off work for training, and where companies cannot afford to pay for face-to-face training for everyone, or arrange the logistics in order to have hundreds of staff away from their desks. I do understand all of that, honestly I do – and I can see that CBT is a good second-best for such situations. But it is second-best.
And what worries me most about it is that, because of the large numbers of staff concerned, it is generally the only logical option for our biggest firms – our mega-banks, our Big Four accountancy firms, our Magic Circle law firms. And because we are all reasonable people, we say, well, that’s all they can do; we can’t really expect Barclays, for instance, with its 150,000 staff worldwide, to given them all face-to-face AML training. But just think about it: which organisations are most frequently targeted by criminals looking to launder their money? The mega-banks, the Big Four, the Magic Circle. It’s not much of a risk-based approach, is it – accepting that the staff of the most at-risk firms will not receive the very best training on offer? If such firms can get away with saying that they have too many staff to train them to the highest standard, how long before they start claiming that their high volume of customers and transactions means that they surely can’t be expected to do the same level of due diligence as their smaller competitors?