Brace yourselves: this is going to be one of those posts where I have a vision of how it is all going to tie together, but it will take time. I was at an event recently where I was told – to my combined delight and horror – that “everyone in AML reads your blog”. I was entirely unaware of this: the only stats I get are from WordPress, which informs me that I currently have 1,006 followers; I have no way of knowing how many people are reading my posts on LinkedIn (to which I copy them automatically) or because other people have forwarded them. So “everyone in AML” – that’s unexpected. I am hugely gratified, of course, and would like to claim particular brilliance, but as with most things in my life, I think my success can be put down to stickability. I am a great sticker-at things: once I start a project, I will always finish it. (I bought a car in 1985 and still drive it today; I met a man in 1984 and reader, I married him.)
I mention all of this not to boast, but because I think it’s the characteristic I have in common with compliance people in general and MLROs in particular: we’re like a dog with a bone. Not for us the quick buzz of a sale and then move on: we like to dig and pick and revisit until we really understand a client or a transaction or a situation. And yet, this tendency is rarely recognised with any admiration: financial institutions reserve their praise for those who bring in profit rather than for those who prevent it being lost (to dodgy clients, or in regulatory fines, or in reputational damage). In an entirely unscientific survey of the current Big Four banks in the UK (please don’t write in), I find that all four are led by individuals who have risen through the sales side of their organisation – not one has a compliance background. Jes Staley of Barclays was in corporate finance and private banking; Noel Quinn of HSBC came through equity finance and commercial banking; António Horta-Osório or Lloyds Banking Group through corporate finance; and Ross McEwan of the Royal Bank of Scotland Group through securities and retail banking (he’s to be replaced next month by Alison Rose, whose career has been in commercial and private banking). Perhaps it’s simply a matter of personality – sales people are better at selling themselves, while compliance people are happier in the background – but it would be interesting to see how a regulated firm would operate with a compliance expert at the helm.
So stickability: that’s the identifying characteristic of my tribe (and therefore presumably many of the “everyone in AML” readers of this blog). Welcome to you all, and thanks for sticking with me: this blog started in 2011 and has continued without a break since then. Perhaps it will turn out to be the part of my AML career for which I am best remembered. At least it’s solved the problem of what to put on my gravestone: Susan Grossey – she really hated money laundering.