I remember my first day at university very well, even though it was so long ago that the whole experience was in black and white. As I was leaving my college to walk into town for the first time, the porter beckoned me over and handed me a piece of paper. On it was a map of Cambridge, with a big red circle drawn around my college so that I could find my way back. “We give this to everyone except the geographers,” he said with a wink. “They get it as part of their final exam.” That was the sum total of my induction, and it came to mind recently when someone emailed me and asked for my suggestions for documents and sources of information to put into a “starter pack” for a new MLRO.
If you were a brand-new baby MLRO, what information would you want to hand? How about:
- Quick link to the FATF website, with particular links to that list of dodgy countries (sorry: jurisdictions with critical deficiencies to the AML/CFT regime) and the latest typologies reports
- Copies of the relevant legislation for your jurisdiction – so for the UK that would be PoCA and the Regs – in both online form (for quick searching) and paper (for highlighting and annotating)
- The telephone number of a friendly soul at the relevant FIU – obviously more achievable in some jurisdictions than others
- Lots of files, folders, stickies, highlighter pens and a fine-tooth comb to go through your predecessor’s AML policies, procedures and logs
- Chocolate – obv.
- Cyanide pill for when it all goes badly wrong…
Any other must-haves?