I like AML legislation as much as the next person – perhaps more, unless that person is an MLRO. If there’s updated AML legislation on the horizon I really look forward to it, and I’ve been on tenterhooks for about eighteen months ever since hearing about changes being proposed in Guernsey. Not just new legislation but also a whole new Handbook of guidance – riches indeed! But timing is all.
Twice a year I run a full-day MLRO workshop in Guernsey – and the second one of 2018 was last Thursday. Of course I have to prepare my material weeks ahead of time, to allow for print-outs to be duplicated, put into folders (that’s a fun morning chez Grossey) and then posted to Guernsey. Plus – perhaps more importantly – I have to know what I’m talking about at the workshop. So you can imagine my delight when the new legislation (in draft-but-fairly-final form) was released on the Friday before the workshop. Worse, it turned out to be only the opening salvo of the week from hell. Let me elaborate:
- Friday 9 November: Guernsey releases significant new AML legislation
- Monday 12 November: I fly to Guernsey and – while I am in the air – the Guernsey Financial Services Commission publishes its new (311-page) Handbook
- Monday 12 November: the Sixth Money Laundering Directive is published in the Official Journal, thereby setting its own transposition deadline
- Tuesday 13 November: the UK government publishes draft legislation outlining what will happen to our AML legislation on what is apparently being called “exit day” (spoiler: nothing, except the global removal of all preferences to the EU, because they will be Dead To Us)
- Thursday 15 November: the husk of a woman formerly known as me presents a workshop covering all of the above material, having had about six hours of sleep each night in order to make time for reading new legislation, etc.
But how kind people are: friends in Guernsey rallied to my aid and made sure that I had a printed copy of the Handbook and handouts containing the updated information. And now I need a lie-down in a darkened room.