I was talking recently to a new client about some training that they had commissioned from me for their staff. I put together an outline of what I thought I should and could cover in the time, including the topics that the regulator would want to see there, a couple of issues that the MLRO had raised as being of in-house concern, and some suggestions of my own, including a short update on human trafficking. The client – I was dealing with the MLRO, but he had to clear it with fellow directors – baulked at this. “Why do we need to tell staff about that?” they asked. “We don’t deal with any human traffickers.” Well, I should hope not – knowingly, at least. But my argument for including what I refer to as “growth crimes” in my training (this year, it’s investment fraud and human trafficking – let’s see what 2016 throws at us) is two-fold.
First, it is a brave organisation – bank, fiduciary firm, legal partnership, estate agency, casino, whatever – that can say categorically that they know that they have no proceeds of human trafficking on their books. What they perhaps forget is that money laundering is a multi-layered activity: maybe you are certain that all of your clients are clean, but are you equally certain that all of their clients are clean? (I am old enough to remember those VD warning campaigns, reminding us that when we slept with someone, we were also sleeping with all of their previous partners. The bed soon became rather crowded.)
And second, I am particularly keen on getting people to care about – indeed, be angry and incensed about – money laundering, rather than simply seeing (loathing?) AML as an administrative necessity. If we can show staff that money laundering involves the proceeds of the most ghastly crimes – perhaps even things that they would rather we didn’t talk about, like the sexual exploitation of children or the sale of human body parts – then it might make them realise why it matters so much that we do all we can to prevent it.