One of my favourite publications of the year has just appeared. No, not the Donny Osmond Christmas Annual, but KPMG’s “Global Anti-Money Laundering Survey“. (Actually, it’s not an annual publication but only triennial, so this really is a red letter day.) To set the scene, the survey was distributed to “AML and compliance professionals in the top 1,000 global banks”, of whom 317 submitted responses. The resulting report is full of juicy statistics to scare the Board and educate the staff, but today I am concentrating – for obvious reasons – on the rather scary training findings.
Even amongst the firms employing those AML and compliance professionals who care enough to think about things and respond to a survey, only 62% give their Board any AML training. Can I stamp my little training trotter and just say this: how can directors (NEDs or otherwise) meet their overriding AML responsibility of confirming that their firm’s AML approach is appropriate and proportionate to the current AML risks facing it IF THEY DON’T KNOW WHAT THOSE RISKS ARE? And if the Board cannot be bothered to spend time on AML training, how can they be surprised if other staff treat it with contempt? Stamp stamp!
And talking of other staff, the survey also revealed that 86% of respondents confirm that their employers provide AML training to front office staff. *stand by for further trotter-stamping* SO WHAT ABOUT THE OTHER 14%? This means that in a significant proportion of the world’s top 1,000 banks (so we’re not talking about tinpot institutions, or about recent entrants to the AML family), the front office (client-facing!) staff are not given AML training. Never mind stamping – it’s a veritable trotter-tango in Grossey Mansions today. Olé!