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.