Maybe it’s because it sounds like complaint, but I often encounter the assumption that people who work in compliance are dreary, dull fellows, nit-picking and carping for a living, finding fault in other people’s work and lives, and generally being something of a downer. And then of course my particular area of compliance is called ANTI money laundering, and that’s a pretty negative stance to take right from the start. But I have worked with compliance folk for decades now, and I can say that they are anything but dull. You remember Henry, the mild-mannered janitor who – after hours – climbed into a filing cabinet and transformed into Hong Kong Phooey, scourge of the criminal class? Well, I reckon he was something of a prototype for today’s MLROs, compliance officers and money laundering investigators.
And here’s proof that AML people are not, contrary to the jibes of the sales department, boring “business prevention officers”. Dana Reizniece-Ozola is a 36-year old chess player of some standing; indeed, she holds the title of Woman Grandmaster and her current world ranking is 2,292. She studied International Business in Finland and law in Latvia before gaining a master’s degree in translation and then an MBA from the International Space University in France. A smart cookie, as they say. Oh, and now she’s Latvia’s Minister of Finance – which makes her responsible for overseeing her country’s AML efforts. This is no cushy number, as you can imagine. Among the key findings in the most recent mutual evaluation of the country, published by MONEYVAL in July 2018, were the observations that “unusual transaction reports and suspicious transaction reports are not fully in line with Latvia’s risk profile and their quality appears modest” and “the appreciation of ML/FT risk in the financial sector is not commensurate with the factual exposure of financial institutions in general, and banks in particular, to the risk of being misused for ML and FT”. Scandals involving local banks Trasta Komercbanka and ABLV have kept Latvia in the money laundering headlines. However, it can be no coincidence that since Ms Reizniece-Ozola took office in February 2016, the situation has improved: “Until recently, the judicial system of Latvia did not appear to consider ML as a priority and to approach ML in line with its risk profile as a regional financial centre. This appears to have changed lately to a certain extent, with some large-scale ML investigations underway, involving bank employees having actively facilitated the laundering of proceeds.” It doesn’t take the brain of a chess grandmaster to realise that putting your brightest and best in the positions where they can use their wily intellect to fight crime will have excellent results. Just ask Henry.
I blame the spreadsheets. We spend an inordinate amount of time looking at them, and people seem to think that’s boring (probably because it frequently is). In general ‘though, the attitude to financial compliance all too often seems to echo the attitudes to speeding: “Why aren’t you out catching real criminals, rather than harassing the poor innocent taxpayer with bureaucracy..”; quite how people can be best persuaded to understand that what they view as “bureaucracy” are vital laws designed to protect society from the activities of some deeply unpleasant groups and individuals is the challenge!
I couldn’t agree more, Gareth. It’s funny how people’s attitudes change when they are the victim of the crime – so the person who is injured by a speeding motorist suddenly supports the idea of punishing fast driving, and the one who loses his life’s savings to a conman suddenly wants to know why banks aren’t doing more checks into their customers and transactions!
(Oh, and incidentally, this rather made me bang my head on a desk this morning: https://www.accountingweb.co.uk/any-answers/approved-for-anti-money-laundering-supervison
The comment from the person who didn’t have time to look into it, because they’re “busy with their clients” is, I fear, typical of many attitudes. Let’s hope their clients aren’t up to anything dodgy.)
I’m also worried that someone who claims to be a member of the AAT says of AML supervision “nor have I ever heard of it before today”…