The devil in the detail

I had an interesting phone call with a compliance officer the other day – she will recognise herself in this description.  We were talking about a possible suspicion, and I was impressed by both her attention to detail and her line of reasoning.  The client concerned had given his occupation as “project manager” and then – on his application form – he had made a spelling mistake on his own name.  Perhaps not conclusive evidence of evil but – as this compliance officer said – aren’t project managers meant to pay close attention to detail?  Aren’t they meant to be super-organised and to double-check things?  And this made me think about what we can deduce from the smallest pieces of information that clients share.

Often it is not the single detail but rather the whole picture.  If someone says that they are a homeowner, aged twenty-nine, with no mortgage, does that sound odd to you?  What if I add that the average period for repayment of a (UK) mortgage is 25 years, and moreover that the number of first-time-buyers taking out a 31- to 35-year mortgage has doubled in the last ten years?  Now I hope you are considering some source of wealth enquiries.  What if you run an online gambling business and over a period of a year one of your customers bets £850,000 with you – after saying on his application that he is an accountant?  Do you know how much an accountant earns?  I’m guessing that the staff at Betfred didn’t…  (To get a ballpark figure for most standard jobs, you can try the Payscale website.)

But, as my compliance officer friend demonstrated, it’s not just matching earnings to assets.  Yes, a project manager should be good at details.  In the same vein, an English teacher should have perfect spelling, an accountant should be adept with numbers, and a doctor should have an illegible signature.  (Only kidding – my doctor has lovely penmanship.)  Does the work address fit with the home address?  (Ask them about their commute – that will soon tell you if they’re fibbing about one or the other.)  If they claim to have no landline, is that likely – yes if they’re a twenty-year old Youtube influencer, no if they’re a seventy-year old vicar.  In short, we need to remember that we’re not collecting random details just to fill spaces on a form: we’re gathering pieces of a jigsaw to assemble a coherent picture.

This entry was posted in AML, Money laundering and tagged , , , , , , , , . Bookmark the permalink.

One Response to The devil in the detail

  1. CDWOS says:

    maybe those of us who have been around a tad longer are missing the point of the exercise…………I’m told its “ticking the box”!

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s