Top-level training

First of all, I hope you enjoyed my little April Fool’s joke on Friday…

I wrote a little while ago about the refreshing honesty of the UK’s first national money laundering risk assessment, and now it’s the turn of the Isle of Man.  I particularly like their pithy justification for undertaking an NRA, in its introduction: “The NRA is intended to inform Government policy making and to directly influence the efficient allocation of resources.  Its findings will also help industry, providing a national context within which businesses can carry out their own risk based reviews.”  I couldn’t have put it better myself.

There is plenty of meat in the Manx NRA, and you can read it for yourself, but it has been followed admirably sharply by an AML strategy – that government policy they talked about.  In fact, the NRA and the strategy were released on the very same day.  The strategy is neatly structured, with ten goals identified.  Some are both predictable and wide – such as “Refine national anti-money laundering and combating the financing of terrorism policy making and legislative process” – but it’s the last one that caught my eye.

Goal ten is “Promote training and awareness of anti-money laundering and combating the financing of terrorism within Government”.  Yes: within government.  I’ve always beaten the drum for senior management training, and honestly not just to fill the Thinking about Crime coffers: I genuinely think that staff will consider all the talk about AML rather hollow if those at the top can’t even be bothered to update their own understanding of it.  And the Manx ambition goes even higher than that: “At a strategic level, as an international finance centre it is highly relevant that Ministers and senior officers in particular have an understanding of the [money laundering and terrorist financing] issues so that they are informed when assessing risks to the Isle of Man.”  I’m very impressed, and may just send in my CV.

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