My AML resolutions for 2014

Welcome to my first post of 2014 – and happy new year to you all.  In my last post I looked back over 2013, so it seems sensible to use this one to look forward to the coming year, and – as recommended by all the self-improvement self-help books – I am going to publicise my AML resolutions in order to give myself an extra incentive (i.e. public humiliation) to keep them.

I just love writing, as you know, and my series of Ned the piggy books (explaining AML for non-exec directors) has been well-received.  But I have been wondering whether I should address another group: AML for ordinary staff.  Of course, I spend most of my working life designing and delivering training for ordinary staff, but might a little reference book help them too?  As a fiendish book-reader myself, I always prefer to have a written reference that I can annotate and highlight and check.  So – now that I am a whizz with the old self-publishing malarkey – I have decided that I am going to test the water with a couple of versions (as I think that, to be genuinely useful, such a book needs to be specific to both the jurisdiction and the sector – e.g. UK banking staff, Guernsey accountants).  Any feedback as to whether the idea is a good one or a dog, or which would be sensible test versions, or other suggestions, will be most gratefully received.

A while ago I did one of those career/personality tests.  (I have two left feet and the singing voice of a dying macaw, so that rules out “Strictly” and “X Factor” – these tests are all I have left.)  And the results showed that what I want to be in life is “an expert”, which means that I want to know all there is to know about my subject, and I want to be a source of information for other people.  (Are you rolling your eyes?  You didn’t need a test to show you that about me, did you?)  But I worry that recently I have been stagnating, and so I am determined that 2014 will be the year in which I make myself even more useful and available to the AML community.  And to this end I have fixed meetings with HM Treasury (not the whole thing – just the AML bit) and the National Crime Agency (ditto).  The master plan is to find out what I can do to contribute more fully to their work, and then to jolly well do it.  (Although I suppose I should warn them that I am really – but really – bad at making tea.)

And finally, I am going to turn on my mobile phone.  I know, I know: welcome to the 21st century, grandma.  But I hate my mobile phone: I hate it interrupting me, I hate talking on it in public in case I’m shouting, I hate worrying that someone is overhearing client details that should be private.  And so I either leave it at home or – if my husband makes me promise to take it – I leave it turned off.  I know that this is both perverse and annoying for anyone who wants to find me, so in 2014 I will turn on the blasted thing.  Sometimes.

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7 Responses to My AML resolutions for 2014

  1. Nikki Neal says:

    as to be expected, Susan, you have started the year in the thought provoking manner in which you no doubt plan to continue, thank you for brightening up my day 🙂

    the role of AML functionality within businesses concerns me greatly. the tip of the iceberg-like problem is the labelling of this functionality, namely the dreaded “Compliance Department”. says it all, doesn’t it? in other words, there’s a sh*t load of rules out there, and these people’s job is to shepherd everyone around and ensure their behaviour is conducted within the confines of these rules, liberally assisted with copious quantities of check-lists and many rainforest’s-worth of procedures. and of course the regulators love all this, and they love to fill their own check-lists, to ensure that everyone else’s check-list completing comes up to scratch.

    occasionally, some bright spark at the regulator says “hang on a minute…shouldn’t we be adopting a risk based approach?”. and everyone nods their heads in agreeement, more check-lists are devised and everyone carries on basically the same as before.

    meanwhile when some not-so-bring person completely outside the check-list regime decides to help themselves to £2.6mil of public money – well, clearly it’s a doddle, because everyone was so busy completing checklists that their eyes were completely off the ball.

    so the problem is that every organsiation already has its own regulator-approved “compliance manuals” for ordinary footsoldiers like myself. it may well be a simple “cut and paste” job cribbed from something written for other businesses with wholly different needs, it may not in reality address the real risks that undoubtedly exist. but really who cares? boxes have duly been ticked to the satisfaction of the regulator and everyone moves on.

    as you can see…I’m not being helpful in terms of arriving at an effective anti-AML solution. I’m just keenly aware that the current efforts which I observe real-time are about as effective in managing risk as all those brainwashed airport luggage-scanning operatives ruthlessly plucking bottles of formula milk from infant’s mouths in the deluded belief that somehow this is making the world a safer place (dear G4 shareholders: I have news for you. the product sucks.).

    suspect there needs to be a dramatic globally-intergrated overhall in the way things are done – time to start peeking into that Alderney bunker and finding out what the hell they’re up to…other perhaps than the island’s customary habit of drinking oneself to oblivion…

  2. Roy McCarthy says:

    Nikki I understand now that above-the-board partying in Alderney is in the quarry while the unregulated stuff goes on in the bunker 🙂 No wonder you left!
    To be fair I believe the CIs are a very small part of the problem. You come onto the radar of the JFSC enforcement boys at your peril. But in many (most?) parts of the world they blink at you with incomprehension if, despite laws and regs being enacted, you talk to them about AML etc. They’re just not interested. If they’re interested there are too few resources.
    It’s too late if dirty money gets this far. It’s the source that needs to be tackled, preventing criminality, policing, justice systems – alleviation of poverty is another target that would help eliminate human trafficking for example.
    I’m sorry to say I don’t see much progress despite all the good intentions.

  3. Jane says:

    I love the book for ordinary staff idea – I’ve just moved into banking from Trust (in Guernsey) and am finding it a bit harder from the AML side. In Trust it’s easier to spot something out of the ordinary when you know the background of a client, but now I’m only seeing a small part of the picture, I’m not exactly sure what is expected of me.

  4. Claire says:

    Welcome to 2014 with your mobile phone! 🙂
    I agree with Roy on the prevention. I think I’ve mentioned this in the past already, but what I would like to see one day, is a book explaining AML to our young people. If they understand financial crime, what the consequences are and how it harms the economy, they will recognize it when it happens. And hopefully act properly.

  5. Thank you all for your comments and thoughts – I’m on holiday in Tasmania at the moment, and having just visited one penal colony (Sarah Island) and now planning a trip to another (Port Arthur), crime and punishment are very much on my mind!
    Very useful comments about my new book idea… Welcome, Jane – please do carry on commenting when the spirit moves you.
    And I certainly agree that tackling the problem at source (educating young people, reducing poverty, etc.) is the ideal goal.
    Not sure how I feel about being part of the box-ticking, regulator-approved compliance culture described by Nikki – but there’s no denying that I am!
    Best (and thoughtful) wishes from Susan

  6. Des says:

    i have worked in various sectors within the finance industry and have found that the audience for AML awareness and training will only sit up and really “get it” when i use anonymised examples within the previous year that involved the company itself. This goes deeper than being specific to the sector and jurisdiction.

    By highlighting how an attempted or confirmed fraudulent or suspicious transaction was identified, through to how it was reported and subsequently handled by the reporting officer, and providing positive feedback as to whether the account was blocked, closed or re-opened but monitored, the audience reacted to how it touched them, their business area and the company itself and would ask many more questions making my presentations more of a two way conversation.

    Typologies always help to bring the subject to life and also provide the added benefit of bridging the gap between the stock phrases ” it does not happen in our business because we only deal in small amounts” and “why should we bother, no one tells us anything after we make a report?”

    I also like to mention that in my role i may also receive requests for further information from other banks or Police forces across the UK and Europe, and in a small number of instances I am asked to appear as a witness in a subsequent court cases and therby can provide more examples at their next awareness sessions.

    Your idea of a reference book is excellent, i beleive that the relevance to the reader is just as important as the main subject. If you can write them in the same way as you write your posts you will have a surefire hit for 2014.

  7. Pingback: This little piggy went to Guernsey | I hate money laundering

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