It’s amazing what public opinion can do – let’s just say George Galloway and cats, and leave it at that. Today I was browsing a motley assortment of websites, buying cat food and train tickets, and something caught my eye: two of the sites I visited had a prominent link to their policies on modern slavery. Here’s the one for Pets at Home, and this is Greater Anglia’s. You can probably guess what I’m thinking: why don’t they give similar prominence to any AML policy they might have?
Now I do see that there is a difference: both of these companies are required, as they state, to abide by the obligations of the Modern Slavery Act 2015, while neither of them is (I should imagine) covered by the Money Laundering Regulations 2007. But their staff are – along with every other adult in the UK – eligible to be prosecuted under the main money laundering offences of the Proceeds of Crime Act 2002, and moreover many of those staff will be handling money on a daily basis (either dealing with customers, or processing company accounts) and so arguably it would be wise for them to have at least considered the matter.
But perhaps it comes back to our old problem, that secretly some people rather admire financial criminals – tax evaders in particular, but also those who dream up clever investment scams and rip off rich people, and those who find a way to diddle large corporations like insurance companies. On the other hand, I doubt there is much admiration for modern slave-traders. No-one is going to refuse to buy cat biscuits from Pets at Home because they “have undertaken a group wide risk assessment to highlight any areas where [they] may be vulnerable to the risk of modern slavery and, where necessary, will strengthen [their] processes in the areas highlighted”. And no-one is going to drive rather than take a Greater Anglia train because they “do not use any forced labour [and] in order to ensure the prevention of modern slavery in the supply chain, [they] review each supplier on a risk basis”. But if a shop were to declare that “we will take immediate and merciless action against any customer who appears to be a tax evader, fraudster, shyster, trickster or scam artist of any kind”, it might be a different story.