I am in reflective mood. Over a recent wet weekend my husband and I tidied out our loft. (I know: not for us a glamorous mini-break in San Tropez.) And amongst the usual broken suitcases, comically out-of-date clothes and half tea-sets inherited from elderly relatives, I found some interesting documents. There were two wedding invitations from couples now long divorced. There was a clutch of cheque books and other paperwork from not just accounts closed, but banks defunct. And there were my very first school reports (“Susan expresses herself clearly in mature language, but struggles with her numbers” – almost literally the story of my life).
As I say, reflective mood. For things are changing in my work life too. This year, for the first time since 2006, I am not making my annual trip to Gibraltar. For twelve years I visited that fine isthmus, providing public AML training under the banner of their local compliance association, and drawing crowds – crowds, I tell you – of hundreds of delegates. But over the entire twelve years, this extravagant display of my wares did not lead to a single in-house booking for training, and so I have decided that it is a poor use of my time to keep up with Gibraltar AML developments and money laundering concerns simply to furnish ammo for three days of training a year. I am mulling the same situation in Jersey: I have about four loyal clients there, whom I visit once a year, but is it enough to warrant keeping the jurisdiction in my armoury?
And so to Guernsey. Guernsey has always been the mainstay of my AML training, with clients there regularly and reliably filling five weeks, and sometimes six, of my time each year with in-house training. And the jewel in my Guernsey crown is my advanced workshops for Guernsey MLROs, which I run twice a year. These are terrific days from my perspective, as it’s my highest-level training, exploring new topics and new ideas in great detail, and debating them with MLROs at the top of their game. For several years, I have filled both workshops to capacity: twenty-four MLROs on each. Until now. I am running a workshop at the end of this month, and numbers are significantly reduced – only thirteen signed up, despite the usual marketing efforts. And so I wonder: why? Guernsey is awaiting new Regulations, apparently due out in June and to be implemented in September – although that’s only hearsay. Are MLROs hanging fire for the new Regs (which would take up no more than an hour of an all-day workshop anyway), or is it something worse? Has the regulated sector run out of money for training? Or have I reached my sell-by date in Guernsey? Am I the AML training equivalent of a bittersweet, once-cherished but now superseded wedding invitation? Sob!
(And in case MLROs in other jurisdictions are feeling left out, I should say that I have tried to run similar workshops in Gibraltar, the UK, Jersey, the Cayman Islands and the Isle of Man, but take-up was poor.)
I do not receive any invites, so I would appreciate if you could add me to your mailing list for Guernsey.
sorry to hear that upon realistic(?) reflection and review the numbers are dwindling. As you say we have never really been on your A list as presumably the competition here has due to its immediacy if nothing else got there first and grabbed the available budget. On a more serious note I hearing that in Jersey there is and has been a distinct lack of enthusiasm by Compliance and AML people to take on ‘registered roles’. The increased criminalisation of the roles was being proffered as the most likely reason although the comment was added that those who really knew and understood AML & Compliance were closing in on retirement and simply were not prepared to accept the “hassle” and ‘worry’ attaching to such roles. If one is to believe what was being said there is a limited follow through looking to replace the ‘long in the tooth’ would be retirees!. Not a great position to be in but unless the salaries for such roles increase dramatically why should individuals take the risk that were it all to go horribly wrong their livelihood could be removed with all the follow through rehabilitation problems attaching to a criminal conviction and possible custodial sentence.
Goodness what a gloomy outlook……………….didn’t even notice that when chatting to said individual.
On a brighter I would have thought that EU 5 (EU 6 looming!?) should produce plenty for you to train on and about without leaving home(!!) particularly as the UK so spectacularly failed to properly implement EU3 and I understand that not such a great job has been done on EU4 either ( but you better placed to comment on that!).
Have a brilliant weekend doing whatever brightens your days
I think you are right on two counts, CDWOS, but overly optimistic on the third. Yes, I am up against stiff competition in Jersey, with those “on the ground” having the home advantage. Yes, many of the died-in-the-wool AML-ers are approaching retirement, and youngsters are unwilling to take on huge legal responsibility without additional financial reward. But sadly, I can’t picture a huge up-tick in demand for AML training here in the UK, despite the spectres of EU Directives tomorrow and tomorrow and tomorrow. Of course there should be, but I think regulated minds and budgets will be focused on post-Brexit survival, and not on AML. If you’re of a mind to, this is the prime time to become a financial criminal in the UK… But despite all of this, I will enjoy the coming Bank Holiday sunshine!
That is an interesting response from CDWOS. It shows an unintended (I guess) consequence of heavier compliance and AML regs. It shows the problem of strict liability.
While I am neither an MLRO or a CO (or whatever they are to be called in future), I am often heard opining that it will soon be the right time to retire from non-exec positions in regulated companies.
PS: I don’t do facebook or twitter or any other toxic stuff so I don’t know if my comment will get through.
Thank you for your comment, Richard (which did get through!), and welcome to the blog. Yes, it is a conundrum. On the one hand, we need people to take their responsibilities seriously and know that they will be held accountable for negligence, while on the other we don’t want them punished if they make best endeavours but are caught out by a wily scheme. Something for the courts to debate, I fear.
Do not fear we still want to see you in Jersey, I am afraid that JIBS are treading in your territory!
Victoria Wilkinson, MICA
Compliance Manager, Compliance, Corporate & Private Clients
Link Asset Services
12 Castle Street, St Helier, Jersey, JE2 3RT
+44 (0)1534 847319
+44 (0)1534 847001
Part of Link Group
Oh dear Susan. I presume you’ve looked at nearer year end when people are panicking over getting their CPD points? I know that AI is threatening all our jobs but I don’t think they’ve made a robot yet that can deliver AML training.
In the past, Roy, the May date has worked brilliantly: not a busy year-end for anyone, outside school and public holidays, a light and optimistic time of year… And let me know if you do find out about the AML robot – I may be able to pass on a few tips!
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