In a normal AML training session I do not have time to deal with the more philosophical aspects of the subject, but when I run extended workshops – as I have been recently – there is scope for delving into the “why” behind the “how”, “when”, “where” and “who”. And I have had something of a revelation.
It is no surprise to anyone that there is an ongoing tension between the sales side of a business and its compliance effort: one is tasked with bringing in the business, and the other is tasked with turning away some of that business if taking it would be too risky. I had always assumed that this tension was down to profit, but on reflection I think it runs more deeply than that – profit is just the convenient argument that is used to express the deeper differences.
We all know that compliance people are more cautious by nature – if you’re a risk-taker, you don’t sign up to work in compliance. But there are other key differences. Compliance people are good with detail and with concentration: they enjoy the challenge of finding answers to questions and getting evidence to confirm (or indeed refute) what they have been told, and they’re willing to spend hours on that challenge. Sales people, on the other hand, prefer the big picture – they think that details will bog them down and slow their progress in pursuit of their goal. Sales people love the chase, the thrill of landing a new piece of business – but the adrenaline rush fades quickly and then they’re on to the next target. In other words, they are fantastic at starting things but poor at finishing them. And this is where the compliance person shines: compliance people get enormous satisfaction from tying up the loose ends and completing the picture. (They’re probably ace jigsaw-puzzlers.) We’re all slaves to evolution: the ancestors of the sales team were hunting down the next mammoth, while the forebears of the compliance department were back at base, skinning and dissecting the previous mammoth and deciding how to share it out and store one of the haunches for leaner times.
Of course this is a simplification and generalisation – we all know exceptions. But when an MLRO finds himself once more (as inevitably he will) in stern conversation with an account manager who is dragging his heels on those CDD checks, it may be some comfort to reflect that perhaps it is not a deliberate attempt to thwart AML efforts: it’s simply how the fellow is made. And a bit of empathy on both sides could make the relationship less fraught – and may help the MLRO design procedures and training that can present the requirements in a light that is more attractive to sales-minded, mammoth-hunting colleagues.