Last weekend I was in Edinburgh and – trying to escape the festival hordes – I ducked down into Princes Street Gardens. Despite the aforementioned hordes, the gardens were immaculate – every lawn edge clipped, every flowerbed weeded and every path swept. I saw a cleaner wheeling his trolley and broom and decided to compliment him on his excellent work, commenting that it must be particularly difficult when the city is so busy. “Och no, lassie,” he said (really, he did: this post is not sponsored by the Scottish Tourist Board), “it’s not the visitors who make the mess – they see how beautiful it is and they want it to stay that way. It’s the locals and the office workers, who come in here with their sandwiches at lunchtime, and leave their rubbish everywhere. They just don’t see it any more.”
Primed as I am to find an AML message in almost anything, I was struck by the relevance of his observation to due diligence and monitoring. We all spend hours at client take-on, asking questions and doing background checks and verifying documents. So that’s like seeing Edinburgh Castle for the first time, and marvelling at its size and location and majesty. And then, when we’ve known that client for years, we stop not only marvelling at them, but perhaps even stop noticing them at all. Ask an Edinburgh resident whose statues appear on the castle gatehouse, and they probably won’t be able to tell you, because they have stopped actually seeing it (Robert the Bruce and William Wallace, in case you’re interested). And criminals count on this. (No, not on Scots ignoring the gatehouse, but on our taking our clients for granted – do pay attention at the back.) They lurk around in our financial institutions, acting for all the world like nice normal clients, until we stop taking any notice and then wham! They hit us with their laundering. So next time a member of staff says that they didn’t need to do their monitoring because “I know that client so well”, feel free to tell them about my lovely Edinburgh street cleaner.
I hate money laundering 