I wonder if anyone has ever invited Rory Sutherland to be an MLRO? I ask only because several of his recent Wiki Man columns in the Spectator magazine, although ostensibly about (I think) psychology as it relates to business and consumers, have given me all sorts of AML-ish ideas. The one dated 7 May 2016, for instance, is entitled “Tea and honesty” and discussed the moral obligation placed on us to behave honestly and ethically to someone who has been generous to us. His argument is his to make, and he makes it very well, but what pulled me up short was this: “It is human nature to feel far more shame in overcharging someone who buys you lunch that in skimming profits from the face owner of account number 567842/06b.”
Hmmmm. If we transpose that, so that “overcharging” becomes “laundering money through”, perhaps we can turn this to our AML advantage. If indeed, as Mr Sutherland concludes, “you risk greater shame and moral outrage for cheating a benefactor than a stranger”, this could be a fairly efficient and cost-effective way to influence the behaviour of clients (and indeed staff). The example the Wiki Man uses is that of the current vogue for not providing visitors with hot drinks and biscuits, as a cost-cutting measure. But this is a mistake, he contends, as it removes some of the social niceties that foster this feeling of obligation, which in turn can prompt us to behave better. With one eye on the Bribery Act, none of us is advocating a return to eye-wateringly sumptuous expense account lunches, but simply treating a client as a valued and welcome visitor rather than a biscuit-snarfing cost-centre would be a good start. And if staff are treated with generosity and dignity rather than – as in one office I visited recently which shall remain nameless (and soon, no doubt, staff-less) – told that bottles of mineral water are to be locked away for “important people”, they will repay the act with good work and loyalty.