Nothing to hide

As you read this, Guernsey is playing host to an evaluation team from MONEYVAL.  This is one of the first fourth-round evaluations being carried out under the new evaluation methodology, whereby jurisdictions will be rated not only on their AML/CFT regimes as they appear on paper, but also on their effectiveness.  You can read more about it here.  Guernsey has been in something of a (justifiable) fizz about this visit; an evaluation visit is stressful at the best of times, let alone one being conducted under new rules.  So Guernsey readers: my thoughts are with you.

That said, I am rather disappointed not to be there myself: being an AML groupie of distressingly large proportions, I would love to meet a team of evaluators.  And I am not alone in this.  When I was in Guernsey a fortnight ago, I spoke to at least three MLROs who were sad that their institutions had not been selected for MONEYVAL interviews.  They are proud of their AML efforts, and wanted (a) to showcase them, and (b) to hear any reactions to them straight from the horse’s mouth, rather than filtered through regulators and reports.  I remember feeling exactly the same way when I was a new teacher and the head-teacher would come and sit at the back of the class to check how I was getting on – although as my head-teacher was a nun, I did have to moderate myself somewhat.  And now that the Vatican City’s FIU is a member of the Egmont Group, I suppose it is always possible that MONEYVAL’s cadre of evaluators could include nuns…