AML fatigue

I am in Guernsey this week – and it’s not wall-to-wall sunshine like on “Island Hospital”, I can tell you.  But I am here for the reason that makes me happiest: to talk to lots of lovely people about money laundering and anti-money laundering.  Tomorrow I am running a workshop for what I call “AML babies” – people new to the compliance world, perhaps recently appointed deputy MLROs or compliance officers, who need to know everything about Guernsey’s AML regime in one intensive day.  In previous years, I have run this workshop twice a year and filled it to capacity (16) each time.  This year I am running it just once – and it’s only half-full.  I shall love it all the more, and the nine of us will have a whale of a time (and all the more cake and biscuits for us), but I am curious about why the take-up is low.

Rather boringly, this means that I ask anyone Guernsey-ish/AML-ish that I meet.  Is it me, I wail pathetically.  Is it a sign of tough economic times on the island, with firms unable to afford external training?  Are fewer people being recruited by the Guernsey financial sector, or by their compliance departments?  Or have I simply trained everyone in Guernsey?  A friend’s husband is a Guernsey fund manager, and his answer chilled my very bones: “AML fatigue,” he declared.  “We’ve just had enough.  It’s all gone too far and we’re sick of it.”

Years ago when I plighted my eternal troth to money laundering, I was warned about this. It’s the flavour of the month/year/decade, people said: you need another string to your bow for when AML is over.  I ignored them, for, dear reader, I loved AML and could not imagine loving anything else quite so much.  Sure, I can knit a complicated cardi (cabling and everything), but it’s not quite the same thrill as saving the world from criminal money.  But is the fund manager right?  Is it all over for AML?  *sob!*