I’m ba-ack! So let’s leap straight in with a complaint. As every MLRO knows, nothing enlivens an AML training session like a story – known officially as a case study. At the moment, staff are lapping up details of “the £16 million Harrods woman” and “the Assad niece living in luxury in Knightsbridge”. But these are the big public stories of high-level political corruption – and arguably not the laundering worries that most people in the financial sector are going to be tackling every day. Moreover, stories make it into the media only when official allegations have been made or – more commonly – once verdicts have been passed by the court. And, as we all know, the “near miss” can be just as good a training opportunity. Quoting lists of “red flag” indicators gleaned from industry reports does not make it real enough for people – it does not make them stop short and think, “That could easily have been me”.
I am frequently asked by clients to include case studies in my training. But they must be relevant to our sector, they say, and they must be current. This is not unreasonable – but where am I to find such stories? Of course I fillet the case studies and best practice guidelines issued by regulators, and I sometimes pinch stuff from other jurisdictions and pretend it’s local. I also ask MLROs if they have any tales from their own organisation – actual laundering, or near misses – and the answer is nearly always this: “Yes, but we can’t tell you about them and we don’t want staff to know.” (Before I get waves of outrage about SARs and tipping off, I mean either instances where concerns were raised and then allayed, or ones where the investigation is now done and dusted.) One MLRO even said that he wouldn’t be happy for staff to know about how a particular laundering scheme had (almost) worked because “it might give them ideas”.
What would be ideal as a training resource is a library of detailed yet engaging case studies. But who could be trusted – or indeed bothered – to maintain such a thing? The Egmont Group – the trade body for FIUs – does some work in this area, but their last set of case studies was published after the Best Egmont Case Awards in 2013. (And these are grouped by jurisdiction and predicate crime rather than by affected sector, so you need to read a lot to find ones that are most relevant.) You can use final notices and best practice indicators from regulators to cobble together stories, but it’s hard work. So come on, MLROs: who’s up for submitting in-house tales of woe, suitably anonymised, to a central repository to be used for the good of all AML training?