It’s a training week for me – one of my favourite ways to spend my time – and it is always particularly gratifying when something I am talking/warning about is featured in the news, preferably on the very day of the training. It makes it all seem (a) current, and (b) real rather than simply theoretical. And this week I have had a double whammy. Yesterday morning I was talking to a group about the SFO’s renewed vigour in their Libor investigations, and by lunchtime it was being announced on the news that charges were being brought against three brokers. Spooky! I was quite happy to be proved right about that one, but I have rather more mixed feelings about the other confirmation of my training.
In the portion of the training that I like to devote to current criminal activity- i.e. updating people’s understanding of the priorities of your modern baddie – I have been talking a lot recently about the particularly unpleasant trade in human beings and their constituent parts. Human trafficking and smuggling, slavery and organ trafficking are all on the increase, I insist during training. And as if to demonstrate that I am not simply going for cheap scare tactics, two stories very close to home have been in the news this week. In the first, a major investigation is underway into what the press is calling a “slave farm” in South Wales; at the time of writing, three men have been rescued from slave-like conditions, and three people have been charged with servitude offences. And in another part of the UK, a people smuggler in Glasgow has just been ordered to repay the £700,000 of criminal proceeds she made from her ghastly trade in illegal immigrants. Much as we might wish to tell ourselves that such crimes – although upsetting – at least belong to another time or place, we have to face facts: they are here and now. It is only by recognising this that we can design the best AML response to such crimes. And it is only by making staff care about such crimes that we can get them to implement and uphold that response.
Couldn’t agree more. With the best will in the world AML/CFT issues are low on most staff’s priority list and making it real and relevant is the best way of sustaining the standards necessary. A ‘shock’ video now and again is good 🙂
Thanks for your support, Roy – always gratifying when a real-life MLRO confirms that I’m on the right track! And I’m always recording bits from radio and telly to use in training, to demonstrate that it’s “here and now”, and not some theoretical but rare danger.
Best wishes from Susan
Agree with tying it into real cases. Be careful to choose ones where you know the sentancing, or the class might get disheartened when they read later the bad guys got off with a conditional and kept most of their houses….
Never mind the class getting disheartened – so do I sometimes! Thankfully I think both public and political tolerance for white collar crime is diminishing, and we are starting to see individuals being hit with harsh penalties.
Best wishes from Susan