My clients are self-selecting, by which I mean that I am lucky enough to work only in those organisations that care about AML. To be blunt, if a firm is sailing close to the AML wind, it’s not going to let its MLRO (who may not care much either) spend money on an external trainer or someone to help vet their AML policy and procedures. So generally I work with very engaged, determined MLROs who have the support of their colleagues.
But lately I have noticed something of a trend – not a fashion, certainly, and definitely not a movement, but a little bit of a vogue. Recently I have been in to a few firms, delivering AML training to their staff, and the MLRO has not attended. Now if I am doing a full day of training, as I often do, repeating the same session four times, I certainly don’t expect the poor MLRO to sit through all four. But if it is only one session, I think I would expect the MLRO to turn up.
The reason I am usually given for non-attendance is that the MLRO knows all of this anyway. Well of course he does – not least because I have sent him the slides beforehand for review and approval. But isn’t he curious to hear all the voiceover that isn’t on the slides? And – much more importantly – doesn’t he want to see how his staff react, and hear any questions they raise? If he doesn’t do that, how can he assess the effectiveness of the training – an assessment that most regulators now specify? What must staff think if even the MLRO can’t be bothered to attend the training – does that suggest that it really isn’t very important? And, heavens to Betsy, isn’t this his subject? Honestly, I would go quite a distance to listen to anyone talking about AML – you never know what new info you might garner.
I must stress that this is rare: the vast majority of MLROs do attend, and some stalwarts will even sit through those multiple iterations. But I just thought I’d mention it.