As some readers may know, I am a magistrate in my home city of Cambridge. (For non-UK readers, you can read about the magistracy here.) Last week I did a day of training to make me a more effective magistrate, and our topic was “case management”. In short, when someone comes before the court, they plead guilty or not guilty to the charge. If they plead guilty, we try to sentence them as quickly as possible. If they plead guilty, we try to move things towards a trial – again, as quickly as possible. (The mantra: justice delayed is justice denied.) The thing to avoid is having a case appear before us but not being able to progress things at all. All of this is known as case management.
As I was listening and learning, it occurred to me that there might be scope for a similar approach to our AML efforts – client management, perhaps, or CDD management. Might it be useful to have as a goal that every time there is contact with the client, the opportunity is taken to check, edit and/or augment some element of the CDD information on their file? This would make the regular formal review of the client file – on a risk-based schedule – both less onerous (for both institution and client) and less artificial. And of course it opens up the possibility that changes to a client’s CDD that could affect future decisions might be spotted sooner. Due diligence delayed is due diligence disregarded, perhaps.