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?
well the job really has 2 elements:
(a) things that “tick the box” from the regulators perspective (= “being seen to do stuff”).
(b) real risk management, i.e. actions which will keep the Directors and the MLRO out of jail.
as already discussed, (a) can really be outsourced to an “MLRO image management” firm who can put all the necessary windowdressing in place. be sure to keep these boys on a retainer, the regulatory landscape changes weekly to ensure everyone’s still awake, so regular maintenance will be required.
whereas (b) are things that should be done by the Directors anyway, and if the latter are doing their job properly then there’s nothing much the MLRO has to do.
leaves quite a lot of time for the important things in life, e.g. coffee in Waitrose, domestic team management, pondering meaning of life, etc.
think I need a job like that – don’t suppose you do a sideline in MLRO recruitment, Susan…?
I’d love to be a fly on the wall at any MLRO job interview you might attend!
Best wishes from Susan
I would add some real life situations. Because on paper it looks different than when it is happening to you, and all is hush hush. Remember the story I told you about when I was working at a big UK bank in Monte Carlo? And I opened up a safe deposit box for a man with a suitcase of money. The manager had told me not to accept the money, but nothing more. And the “poor” man with the suitcase looked so lost, he could not walk the streets with all that money till after lunch break… The safe deposit box was just for lunch break. Aha, the manager told me afterwards, you just laundered some money. Well, if they had taken the time to help me out, and explain!!!
By the way, when I went to see the bank manager years later (he was the president now), he told me what he remembered most about me was the Belgian chocolates. Haha!
You’re right, Claire – some real-life stories would be useful. Genuine examples of how laundering has really happened in the sector in which the new MLRO is working (banking, accountancy, etc.). After all, there’s no shortage of convictions these days!
Best wishes from Susan
I agree, more case studies required. And cyanide pills.
I’d add one other thing from a UK perspective ….. where a firm is regulated, the name and contact details for the director or senior manager who has been allocated responsibility for oversight of the firm’s compliance with all things AML.
Whilst this can sometimes be the MLRO themself, it is more usually a different person and, in these cases, it should not be forgotten that the overall responsibility sits with that senior manager with the MLRO taking responsibility for more day to day monitoring and oversight.
In an ideal world (where I like to live), a brand new baby MLRO should hopefully expect to get a high level of support from their senior manager, as they are both in it together !!
This is an excellent suggestion, Graham. Like you, I choose to spend several hours a day in an ideal world, and an MLRO dwelling here should certainly get lots of support from that dedicated director/senior manager.
Best wishes from Susan