I’ll admit up front that I didn’t think of this post all by myself – but then that’s the beauty of t’Interweb. I keep a list of possible blog topics, including “money-saving tips for the MLRO”. And then today an update drops into my inbox saying that a very helpful chap called Joe Murphy, who works as the Director of Public Policy at the Society of Corporate Compliance and Ethics in America, has published a marvellous little pamphlet called “A Compliance & Ethics Program on a Dollar a Day: How Small Companies Can Have Effective Programs“, and I commend it to you.
[Incidental aside: the word “pamphlet” makes me shudder. I have a friend who can’t bear the word “gusset”. Do you have words that you loathe?]
Mr Murphy’s pamphlet oversells itself a bit, rather like those guidebooks of old; sure, you could see Europe on a dollar a day, as long as you didn’t want to sleep indoors, or eat. Most of the compliance and ethics suggestions given in the pamphlet do indeed cost nothing in actual hard cash, but most of them have a time cost associated with them. That said, I think that the pamphlet [I’m writing the word pamphlet a lot, to desensitise myself – it’s not working – aaaargh!] is in itself a great time-saver (and therefore money-saver) as it is in essence a very handy and succinct list of reminders.
So how can the frugal MLRO keep his AML costs to a minimum? My three top tips:
- Share information and experience with other MLROs – I know from my own experience that the more generous you are with your own information, the more people are willing to share theirs with you.
- Keep an MLRO diary, detailing when you are going to deliver training, submit reports to the Board, attend updates for your own education, review your procedures, etc. This saves panic, and duplication of effort.
- Subscribe to as many free newsletters and alerts as you can, and then cull the ones that don’t deliver the goods. Even if the alert sends you only a headline and wants to charge you for the full story, you can at least make an informed decision.
And of course the money you save can then be spent on essentials, such as face-to-face training for key staff, and Jaffa Cakes for the compliance team.