At the end of each year I do a stock-take of my piggy sales – by which I mean, I add up how many copies of I have sold of my two suites of AML books for non-exec directors (i.e. those with AML oversight and steering responsibilities) and for staff (i.e. those with AML implementation responsibilities). The NED piggy comes in five flavours (UK, Guernsey, Jersey, Isle of Man and generic international), while the staff piggies come in a wide combination of jurisdictions and sectors. They’ve been on my mind recently because luckily I was able to fill that peculiar week between Christmas and new year with updating all the UK piggies to reflect Brexit – black armbands on their little trotters, etc.
So how did we do in 2020 with rehoming our little piggies?
- The NED piggies are moving very slowly – eleven in the UK, five in Guernsey and one international only, and no interest at all from Jersey or the Isle of Man. But with directors being fined more regularly for failing to engage fully with their AML responsibilities, the piggies and I live in hope.
- The staff piggy picture is more complicated because there are seventeen versions of the book. Still, I can see straight away that not one of the four Gibraltar piggies sold a single copy. We did only slightly better in Guernsey, selling ten piggies – six of those to the fiduciary sector. Jersey was a bit more piggy-friendly: 31 piggies moved to the sun-drenched shores of St Helier, with 23 of them sharing their new homes with bankers. But top destination for piggies was once again the UK: 185 porcine adoptions took place – with the banking sector taking home 143 piggies. Only four piggies moved in with UK estate agents.
I have made a push for the Brexit-ready UK piggies, sending notes about them to all the relevant trade bodies – with a particular plea for help to those representing estate agents and letting agents (with the recent headlines about continued high-level laundering through the UK property sector, surely they would welcome a bit of book-learning). Of course, the Brexit changes to the piggies are not seismic, but it would be handy for an MLRO to be able to demonstrate to a regulator that staff have the very dernier cri in AML info. (In protest at being dragged out of the EU I plan to use more Continental turns of phrase – call it self-Schadenfreude.) But so far, only four UK piggies have left the pigsty in 2021 – perhaps they’re under lockdown.