If only common sense were more common

Stories about Phuket always get a snigger, but one caught my eye this week because it illustrates so well a basic AML skill that we all have (well, should all have): common sense.  The Phuket News (enough sniggering now, thank you) reported that police are looking into the assets of over a hundred “unusually rich” taxi drivers in the town.  Apparently these drivers have accounts containing “hundreds of millions of baht” [100 baht is worth about £1.80], and police believe that much of it was obtained dishonestly.  And why do they think this?  As I used to say when I was a teenager, and therefore knew, like, everything: well, duh!  They’re taxi drivers, and in a small provincial town in Thailand – we’re not talking Zurich limos here.  So the Phuket police (seriously: sniggering all done now) are applying simple reasoning: such volumes of money cannot be generated by the stated employment, so questions must be asked.

In the UK, we have a really weird relationship with money.  If anyone asks how much we earn, we turn a very peculiar colour, harrumph a bit and comment on how it’s a bit warm for the time a year.  In Singapore, where I grew up, it is an entirely normal question, asked on a daily basis, with the answer exclaimed or commiserated over as necessary.  And yet we in the UK are acutely aware of the price of things: estate agents advise clients selling properties to borrow an expensive car to leave in the drive, to make the entire house look more desirable – apparently BMWs and Mercs are the ones to choose.  “Property porn” shows are taking over the telly schedules, as we watch people buy a wreck and then make a killing/gut-wrenching loss as amateur “developers”.

Why then are we in the AML community so reluctant to advise our staff to use their nous when it comes to people’s money – and particularly their income/savings?  If a client or applicant is a hairdresser or a teacher or a doctor or an airline pilot, it’s pretty easy to find out the average salaries for such jobs.  And then it’s a short step to checking that their income/savings fit with that.  After all, why else do we even ask about people’s employment?  Sure, it’s probably a bit rude to ask about someone’s money over the dinner table, but the rules are entirely different in the professional environment: if someone wants your firm to help them with their money, they have to tell you about it first.  And having staff apply their common sense – the sniff test – to the answers to those questions is such a quick win.

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2 Responses to If only common sense were more common

  1. come on! the NSA knows who everyone is - you dont need to says:

    One of the factors making this approach difficult is the years of media and government indoctrination against ‘judging’ someone. Examples would be the recent fuss of Farage saying that a bunch of unemployed Romanian men moving in next door is a different risk than a German family. He got attacked. I say it’s just good application of experience.

    I remember one AML course where a staff member put in a racial discrimination compliant against the MLRO (not me!) because one of the cases involved a politician from her home country being corrupt. She said to use the case at all – all factual – was racist.

    So using the sniff test has a range of potential HR and legal risks in the west. In the East and Africa, of course, they are much more sensible and in my experience staff make better judgements as a result.

  2. Yes, “profiling” has all sorts of ramifications – as others who use it (e.g. immigration departments) have found. And yet we do already profile on other (non-nationality) characteristics – e.g. if you’re married to a PEP, you’re considered high risk, through no “fault” of your own. We never said that AML was easy – the challenge is always to find that (elusive) balance between what is acceptable, palatable and effective in the fight against criminals attempting to abuse our systems.
    Best wishes from Susan

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