The absent MLRO

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.

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3 Responses to The absent MLRO

  1. Sue Shelley says:

    As a former MLRO, I would expect to sit though all sessions, or at least a part of all sessions…for all the reasons you mention….out of interest and to be able to link the AML information into the organisation’s AML operations. Without this crucial element, there is a risk that the sessions are viewed as merely “ticking the regulatory requirement box”, which does not enable the organisation or individuals to gain the greatest benefit from the training. From personal experience (and I know I am not alone) it could be that the MLROs really want to attend yet are under so much pressure due to financial constraints and increased workloads, that they just cannot allocate the time. Despite all the rhetoric and media coverage relating to increased AML resources in banks, it seems internal AML compliance cultures still have a long way to go…..

  2. Some excellent points, Sue – many thanks. I must admit I hadn’t considered the “time pressures” issue – I had always (vainly) assumed that AML training would be the most important thing in the MLRO’s diary that day, but perhaps not, particularly if the MLRO is also holding down other roles.
    Best wishes from Susan

  3. Sue Shelley says:

    Thank you Susan. Sadly, I know of MLROs outsourcing their training – because – of time constraints even when not holding any non-MLRO roles. Some confided that there seems to be an increasing and worrying trend…whereby their boards/management require so many statistics, key performance indicators etc to satisfy regulators or head offices, yet continue fixing/cutting costs so that they cannot recruit to cover the additional statistical work …..which in turn puts pressure on the “real” AML work, such as training. All the best, Sue.

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