Years, nay, decades ago, when I started out in AML training, I vowed to myself that my training would be different. It would not concentrate on money laundering penalties, or feature the phrases “clapped in irons”, “bread and water” or “say goodbye to your pension”. No: my plan (to which I have stuck) was to concentrate on the why of money laundering and the why of anti-money laundering. Make people care about money laundering, make them angry about it, and they’ll want to prevent it, I reasoned. But it turns out that I might have been wrong.
Just before Christmas an article appeared on the Forbes website entitled “10 Ideas to Curb White Collar Crime” – catnip to me, as you can imagine, as I’m always on the lookout for nuggets of wisdom to pass on to MLROs. And top of the list is this: “Ditch Ethics Training For Teaching Federal Sentencing Guidelines – Every white collar felon I [the article author Walter Pavlo, himself a white collar felon] talked to over the years, and I have talked to many, had never heard of the guidelines used to sentence people to federal prison for white collar crime. People would make better decisions of choosing right over wrong when they clearly understand the consequences.” So perhaps I shouldn’t skate so quickly over the penalties, with my usual, glib “…and fourteen years on offer for this one”.