Three of my very most favourite things in the world are delivering training, MLROs and biscuits – so when I can combine the three (as in tomorrow’s workshop for experienced MLROs in Guernsey, with two biscuit breaks) I am a very happy bunny indeed. I have been running these MLRO workshops for years, and they are just the most exciting events: I prepare a ton of information and raid M&S for gingerbread men, but then on the day our discussions range far and wide, and I always learn such a lot. And the fact that some of “my” MLROs are coming to their eighth workshop tomorrow tells me that they find the training useful and correctly pitched.
So when the UK’s Financial Conduct Authority published its thematic review on “How small banks manage money laundering and sanctions risk” earlier this month, I was despondent to read that: “The level of AML and sanctions knowledge among MLROs in a quarter of banks visited was inadequate. In particular, they did not understand their legal and regulatory responsibilities, money laundering risks, or ‘red flags’ relevant to their bank. The MLRO is an essential function and a weak MLRO cannot meet their obligation to oversee their bank’s AML compliance. We found that MLROs in a quarter of banks had a detrimental effect on the overall standard of AML and sanctions systems and controls in their bank. Following our visits, several banks have decided to replace their MLROs.” Those poor MLROs. (And before you suggest it, yes, I have contacted the FCA and offered my training services – but the FCA isn’t really in the training market, and it would be quite a step for them to do it.) I have tried to run my MLRO workshops in London, but I’m not nearly as well-known there as I am in “the islands and isthmus”, and I just couldn’t fill the room. But perhaps now, with the FCA breathing down their necks, UK financial institutions will be more receptive to the idea of dedicated training for their MLROs, and not expect these poor souls just to pick it up as they go along – or not, as seems to be the case. Imagine the horror of being an MLRO while not understanding your legal and regulatory responsibilities! And as for concept of an MLRO actually being detrimental… well, pass the biscuits, as I urgently need reviving.