I went out to dinner last night; I figured that after knocking out the first draft of another AML book (I did mention the other day that I’m working on my UK piggy editions now, didn’t I?), I deserved a plate of spaghetti cooked by someone else. There was a large group of us – some I knew, and some were partners of the people I knew. And one of these unknown partners was fascinated to hear about my line of work.
Now, contrary to what you might think, this is not a good sign. Don’t get me wrong: I am thrilled beyond measure when I find someone “in the business” (i.e. the AML regulated community) who is as bewitched by AML as I am. We can dissect the finer points of record-keeping, consider the ramifications of a wider PEP definition and a public register of beneficial ownership, debate the merits of the objective test, and generally have a high old time. But when it’s a civilian, I am not so pleased. Because I know what is coming.
First I will hear about how some ignorant, unfeeling, pettifogging and probably impotent bank/building society employee prevented them from doing something perfectly innocent by (the cad, the bounder) asking about the source of their money. And then – seemingly unable to stop themselves – they will hint to me about that source. Sometimes, all is well: their squeaky-clean maiden aunt (perhaps a nun) really did die and leave them a fortune. But more often, there will be something just the slightest bit whiffy about it, and this is suggested by the words they use. “Strictly speaking”, or “in some circumstances”, or – my particular favourite – “none of their damn business”. So I listen and smile, craven creature that I am, and store the information away. I think they think that I’m offering a sort of money laundering confessional service – that once they have told me, and I have smiled, they have received financial absolution. It’s a theological matter that they can raise with the prison chaplain; after all, fourteen years should be long enough for that discussion.