Regular readers will know that when it comes to consultations, I am Pavlov’s respondent: tell me you want my opinion and I’m slavering to give it. Indeed, so regular is my participation that I have a whole email folder entitled “Consultations”. (I also have one called “Alliances” and another called “Confrontations”, which reveals pretty much how I categorise my interactions with other providers of AML training and advice.) But my husband works in a very tangential fashion for the Department for Transport and – apart from commenting on an almost monthly basis that “Yes, Minister” was more documentary than comedy – his most frequent observation about the public sector is that consultations are issued in order to be seen asking questions rather than through any desire at all to receive answers.
Thus is my trusting nature abused. Looking at that “Consultations” email folder, I can see that so far in 2017 I have responded to eight consultations: two for HM Treasury, three for the Joint Money Laundering Steering Group, one for the FCA, one for the Guernsey Financial Services Commission and one for the Gambling Commission. Each takes time, of course – some of them a great deal of time – and I do try to be as open and helpful as I can. To think that my responses are just going into a black hole, just a number to be counted rather than a view to be considered, is rather depressing.
But perhaps things are not that bleak. I’ve been away for a month, and on my return I contacted a few people to catch up with the latest news in “my” jurisdictions. In Guernsey, for instance, we are on tenterhooks waiting for updated AML legislation along the lines of MLD4. (I’m off to Guernsey in a week’s time, and live in dread of them updating their legislation two minutes before I arrive, necessitating speedy adjustment of both training material and mindset.) But never fear, said my Guernsey mole: the GFSC received so many responses to their consultation – over sixty, apparently – that they won’t be able to approve updated legislation and guidance any time soon, and perhaps not even before the end of the year. This surely means that those responses are being read and considered, not merely counted. I feel enthused and invigorated, so if you’ve been thinking of issuing an AML consultation of any sort, do it now while I’m all optimistic again.
Dear Susan. Unfortunately, I think that my scepticism is in line with your husband’s when it comes to HMG consultations but then my wife has often branded me a pessimist. That said, I think most pessimists are merely realists with measurable experience…. but then I would say that wouldn’t I.
Many thanks for your comment, David, and welcome to the blog. Knowing you (and your professional background) as I do, I would call you a realist rather than a pessimist. I think all MLROs have a streak of idealism in them, which would be at odds with deep-seated pessimism! Best wishes from Susan
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