May I be honest with you? I have worked alone for more than twenty years and I like it, I really do. As an only child I became used to not having to compromise, and I also have a visceral loathing of meetings, so running a one-person business where I make all the decisions and don’t have to take anyone else’s opinions into account suits me well. But in my little AML-ish heart I have an unfulfilled ambition: I long to be part of a strategic consultative body. I dream (sometimes literally…) of someone from the Treasury phoning me up and saying, “You’ve been doing this AML stuff for a while now, and your perspective on how MLROs actually deal with it is just the angle we need to complete our task force – are you free on Wednesday?”. Ah, let me just pause and imagine that for a moment…. OK, I’m back now.
It has, of course, never happened. I once felt that I knew a chap from the Treasury well enough to ask him, without sounding pathetic and needy (well, perhaps just a bit), why I’m always left on my own in the playground when it comes to picking task force teams. And he said that it’s my very independence that does for me. Because I don’t represent any specific group of people – I’m not from the BBA or the ICAEW or the Law Society – there’s no place at the table reserved for me. And frankly, it’s too late in the day for me to hitch my AML wagon to any particular trade body – I like dealing with everyone. So here I stand, nose pressed against the window, watching the launch of yet another AML task force to which I was not invited *sob*.
On 14 January 2019 it was announced that the (UK) Home Secretary and Chancellor will jointly chair the Economic Crime Strategic Board, which will meet twice a year to “set priorities, direct resources and scrutinise performance against the economic crime threat… set out in the Serious and Organised Crime Strategy”. There are some top people involved: “The board includes CEOs and chief executives from the banking institutions Barclays, Lloyds and Santander as well as senior representatives from UK Finance, the National Crime Agency and the Solicitors Regulation Authority, Accountants Affinity Group and National Association of Estate Agents.” Their first two pieces of business will be to approve both an investment of £3.5 million “to support work to reform the SARs regime” and “additional investment in the multi-agency National Economic Crime Centre”. As ever, I am disappointed to see that there is no-one at the table talking on behalf of the MLROs who have to implement whatever economic crime strategy trickles down to the front line (and be held responsible for its success or failure). If only we knew someone who works with MLROs in all sectors and hears their practical difficulties and suggestions on a daily basis…
I hate money laundering 
Isn’t there a club for MLROs?
Yes, there are a couple here in the UK, Roy, but again, their representatives are not invited to these task forces. Baffling, I know.
Were as my heart just sank when I read the announcement as I wondered “Is this someone’s bright idea at getting-a-promotion-empire-building-ensuring-I-have-private-sector-contacts-when-my-public-sector-career-is-up, by someone who had never heard of the very similar JIMLIT? And so soon after the NECC has been set up too…”
Now I am not saying I am right, but I did note that the day after the announcement there was a follow up announcement that this new task force and JIMLIT would be doing very different things. DIFFERENT THINGS ok? its not just a government mix up you know, its deliberate…
As the announcement put it:
“While JMLIT and the Joint Fraud Taskforce focus on specific crimes, the Economic Crime Strategic Board will have a broader remit.
In addition, whereas the older taskforces work with the private sector on an operational or day-to-day level, the new Economic Crime Strategic Board will comprise of ministers and focus on aspects such as decision-making. ”
That first sentence seems to be consultant speak for “we are different honest…”
Sounds to me like another do-group/taskforce/boondoggle which will work in a silo, duplicate effort, produce well meaning reports but not actually do anything. If we are serious about tackling this area, and we need to be, try making the existing bodies work better rather then inventing new ones all the time.
(Sorry its all very frustrating here at the cliff edge of enforcement).
That’s how I felt about OPBAS, Robert: why put in another layer when the existing layers seem not to be working as well as they could? (I may have just answered my own question…) And you’re right: why yet another task force? But – given that it’s there – I so wanted to be on it! *stamps little foot*
In the (Alas unlikely) event I am ever in a position to do so or have that much influence over my Employer, I will try get you invited to something.
Then you may be sorry!
Aw, that’s kind, Robert – and I’ll even bring the Jaffa Cakes! (I’m of the view that no gathering can be too bad-tempered if there are Jaffa Cakes on the table – they make everyone smile.)