It may surprise you to hear that when I was a teenager I wanted to be, no, not a model or an air hostess (as they were called in the dim and distant 1980s) or even an AML specialist, but a market researcher. We had a family friend who did this and it seemed to me to be a good combination of talking/nosiness (my natural skills) and maths (my father’s area, and of course I wanted to please him). On reflection I would have been hopeless at it – my love is finding one subject and then gnawing it to death – but I retain my juvenile fascination with surveys, studies and reports. Recently LexisNexis (a “leading global provider of legal, regulatory and business information and analytics”) and the Economist Intelligence Unit announced the publication of their analysis into the thoughts of “more than 200 professionals charged with combatting money laundering, to gauge the mood in the trenches” – and I was powerless to resist.
“On the Frontline: The UK’s Fight Against Money Laundering” is free to download and makes interesting – if occasionally disheartening – reading. Looking to the near future, a quarter of respondents felt that the biggest risk to the UK in the fight against money laundering is “evolving criminal methodologies”, such as cryptocurrencies, while 18% cited “geopolitical events”, such as Brexit. On that topic, the report (thankfully) chimes with my own thoughts: “Despite claims by some politicians and some sections of the media that the EU imposes unwanted rules on the UK, the UK has often steered the direction of AML regulation. The UK has led pan-national regulatory developments and gold-plated the results for domestic use. However, despite the UK’s relatively strong AML record, Brexit creates a challenge [including] the potential loss of access to European security databases following Brexit.”
As for how to tackle money laundering, the most votes were cast for “using advanced analytics and emerging technologies” [clever computers], “better monitoring and reporting of enforcement outcomes” [naming and shaming], “more efficient knowledge transfer of existing and emerging money laundering typologies” [case studies] and “tougher penalties on firms and individuals” [big sticks]. Asked about which regulatory initiative would most improve the efficiency of AML compliance in the UK, the clear favourites were “increasing the clarity of communicated requirements between regulator and regulated businesses” and “more frequent communications between regulator and regulated businesses” – which demonstrates that UK MLROs (or at least, the ones surveyed for this report) would welcome a closer relationship with their regulator (something which few of the UK’s AML supervisory agencies – except perhaps the Law Society and the Gambling Commission – currently offer). And as someone who has never made a secret of her motivation – I hate money laundering (look: there it is at the top of the screen, as clear as day) – I am delighted to read that a third of respondents think that companies can better tackle money laundering by “promoting company culture around AML to evolve from ‘preventing regulatory punishment’ to ‘stopping money laundering’”. As I catch up with all the laundering naughtiness that has been going on in my absence, I am glad to be back to play my part.
Susan,, Welcome back. Written standing up no doubt! Seen this report, even downloaded it and read a few pages but not having your tenacity my enthusiasm waned…………………Does seem to do that more often nowadays particularly when being reminded how important a risk or compliance topic that has been around for 30+Yrs is! Must be age or something like that!
As you and the report mention it is interesting (and sad) that after 20/20 years of AML/CFT training and exposure a significant number of long established senior people still believe that talking to a client could be “tipping off”. They seem horrified and dumbfounded when asked how else are you going to get the information that only your client knows??
Just seems to highlight that many of those “who know because they’ve been doing for years” have yet to grasp the basic principles of what AML/CFT is all about.
Indeed: I think more AML training time is spent on explaining what it and what is not tipping off than on any other AML topic. With some people, it makes me wonder how they provide any level of appropriate or tailored service at all, when they are so reluctant to ask any details for fear of appearing impertinent – or of tipping off!
Many thanks, CDWOS – I’ve had a couple of non-cycling days so can sit again! I know what you mean: it’s hard not to say “I told you so”, isn’t it? Let’s just see ourselves as prophets.
I wish these reports, papers, studies etc. were written in plain English Susan – you gallantly tried to translate bits of it above, and you have done your bit with your piggy books. The academics that write that stuff must get paid by the word, with a bonus, like Scrabble, for big words.
I fear that much of it is that when commercial organisations publish such reports, they are trying to drum up business and so they are (perhaps misguidedly) more fulsome and flowery than they need to be, to demonstrate expertise. My favourite sources for beautifully crisp writing – where points are laid out clearly and addressed one by one, leading to a conclusion – are the UK Law Society, and RUSI. The older I get, the less tolerance I have for things that are overblown – I can’t bear films that last for more than two hours, or books longer than 500 pages. I figure that I’m running out of time and need to spend it wisely!