So, after much anticipation, the UK’s National Crime Agency is here – it took up the reins from SOCA (and others) on Monday 7 October. There has been quite a bit written about the NCA’s new responsibilities, but I have been indulging in my own little daydream about how I would like this new agency to be.
Jaffa Cakes at every meeting, obviously. I know there will be concerns about public money being spent on frivolities, but if you buy them in bulk it’s much cheaper (believe me on this one), and the resulting good mood will more than repay the outlay (happy visitors co-operate more and strike better deals). This was one of the major failings of SOCA, I always felt. They might well have had Jaffa Cakes at their meetings – but they never invited anyone else. They were a rather insular agency, to the point of not even putting their name on their buildings. The NCA, on the other hand, is going to be much more – to use an expression popular with the youngsters these days – in your face. As this photo in the Telegraph shows, they have finally achieved their ambition to be kitted out with FBI-style jackets. I’m not fussed about the jackets (beyond observing that a blouson cut may be unforgiving on the more portly agent), but I would certainly applaud a more open and welcoming agency. The best FIU of my acquaintance retains that top position precisely because of its approachability; its local MLROs feel that they are part of a co-operative approach to tackling money laundering, and are certainly not treated as an irritating encumbrance too stupid to be trusted with information.
Yes: as well as Jaffa Cakes and open doors, I also dream of feedback. (I’ve got to get better dreams – I may have to watch “Mad Men” again.) I appreciate all the legal obstacles to FIUs providing feedback, but some manage perfectly well despite this, while others use it as an excuse simply not to try. If MLROs – and by extension their staff – are to be convinced that their (considerable) effort around suspicion and SARs is worthwhile, they need to see some results. And frankly, a colourful pie-chart once a year does not cut the mustard. No-one expects detailed feedback on every specific SAR, but it cannot be beyond the wit of FIU to put together meaningful statistics and interpretations – and then to offer suggested solutions (e.g. “Last year this sector made 24% more SARs than this year. This is unusual in the context of rises in other sectors. We are concerned that staff in this sector are unaware of key current issues, as not one of the SARs submitted mentioned people trafficking or tax evasion, and it might be that MLROs in this sector need to cover those topics in their staff AML training. We will check for changes in this area.”). Woolly, non-specific feedback is a waste of time, for both those preparing it and those reading it. So come on, NCA: let’s have some smart feedback to go with your smart jackets.