At some training recently, we had finished the serious business of the day and were cruising into the home straight with a quick round of my Countries Quiz. As I was asking people to match capital cities to countries, one of the delegates harrumphed a bit and put down her pen. “I can’t see why we’re doing any of this,” she said, “as it’s nothing to do with money laundering”. I had in fact explained to the group that the purpose of the quiz was to revise those countries that are known for good AML controls (we call them “equivalent jurisdictions” here in the UK) and those that have inadequate AML regimes (“high risk jurisdictions”), as the appearance of either in your client relationship will have an effect on the amount of due diligence that you have to do on the client and/or their transaction. I was happy to explain that again, and she seemed mollified, but I did wonder whether I have lost sight of what I am supposed to be doing – i.e. alerting staff to their AML obligations.
Time permitting, I always like to include a “game” in my training. I spend hours – literally hours – reading books about training games and thinking of ways that they can be adapted to AML purposes. And I am quite fierce with myself: there does have to be that AML purpose. Often it is simply revision – an excuse (as when I play AML bingo) to go back over material we have covered in the training. (“Tell them what you’re going to tell them, tell them, then tell them what you’ve told them.”) Sometimes it is a sneaky way – as in the Countries Quiz – to make a dull topic (lists of jurisdictions) more palatable.
But I will be honest and say that I have another, more dastardly purpose. People like games. People like prizes. And if I can end a training session on a high note, with people laughing at the end of a game and enjoying the little prizes, then they will be happier to attend AML training the next time.
I hate money laundering 