At the start of my working life, I did a self-assessment questionnaire which indicated that my strengths lay in keeping myself to myself (a team worker I ain’t) and in learning more and more about less and less – in other words, I should be an expert. The word has become devalued (a has-been under pressure, etc.) but the etymology holds true: it is from the Latin experitus, meaning tried, proved, known by experience. And for nearly thirty years I have concentrated on developing my experience of one subject: AML. When I first told people of my plans, several counselled against it. Money laundering is a fashionable bugbear, they said: it will be solved, or people will stop worrying about it, and then you’ll be out of work. Broaden your reach, they advised: offer training in all the financial crimes and not just money laundering. I ignored them – not because I knew my market so well, but because all other financial crimes seem so ordinary and dull when compared to money laundering.
And it turns out that my advisers couldn’t have been more wrong – but then so was I. They were wrong in thinking that money laundering would fade from view, and I was wrong in thinking that I could master AML. Sure, I think about it all day, most days – and I know the requirements in worrying detail (who knew that one day I too would be quoting sections of legislation as though to the gavel born). But wow, is money laundering growing complicated and specialist. I feel I could spend another ten years getting to grips with trade-based money laundering, and then ten more for cyber-laundering. You remember when your grandma looked at you with astonishment when you programmed the VCR for her? I get the same look on my face when someone talks to me about crypto-tumblers and DeFi.
So what is an MLRO to do? Three things:
- Don’t panic – no-one can expect you to understand every aspect of every form of money laundering
- Subscribe (often for free) to good, reliable, reputable sources of information – for instance, the executive summaries of FATF typologies reports are invaluable ‘idiot’s guides’ to current money laundering hot topics
- Enlist the help of the right experts – no, not me, I’m talking about the 18-year old in your IT department who knows everything about crypto.
From a personal perspective, I’m delighted with my career choice – I can’t imagine anything worse than feeling stale, or anything better than working in a subject that keeps stretching the brain cells.