Today’s question: in what way is an AML trainer like a Catholic priest? Let me set the scene (which I shall keep deliberately vague, for reasons that shall become obvious). Some time ago I was invited in to see a potential new client. At the meeting were the rather harassed-looking compliance director and MLRO. We haven’t given our staff AML training before, they said, apart from a quick online test thing. From talking with our staff – particularly the client-facing people – we are very concerned about their lack of AML knowledge, and have come across several instances where we would have expected an internal SAR to have been made, but nothing has materialised. In fact, we have never had a single SAR, despite being in business for several years. We desperately need AML training. Can you help? Of course I can, said I, taking copious notes. Looking back at those notes now, I see phrases like “money often returned to client no questions asked” and “staff think that small amounts cannot be laundering”. We agreed that I would design face-to-face AML training for their staff. Later in the process, I was trying to communicate with my contacts and had difficulty – no replies to emails or voicemails. It transpired that all the people I had dealt with had left the company, and that the replacements had decided that this AML training was no longer a priority. And that was that.
Of course, this is not the first time I have heard of – or imagined – poor AML compliance within a firm. That’s my job, after all: to help MLROs do this AML stuff better. And it’s not that I suspect actual money laundering, which would be simpler, as I would simply make a SAR myself to the appropriate FIU. I just think their AML efforts are a bit pants. I could give the nod to their regulator, I suppose, but then firms would – quite rightly – become chary of discussing their concerns with me. And it could all be a cover story, which they have wheeled out in order to save the embarrassment of having to explain to me that they have chosen another training option after all. And so, like the good priest, I simply nod and listen – and wish that I could prescribe a few recitations of the AML legislation as atonement.