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 And amongst the usual broken suitcases, comically out-of-date clothes and half tea-sets inherited from elderly relatives, I found some interesting documents.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.)