Sportswear and I rarely coincide, but I am a fan of the slogan “Just do it”. Years ago a much-respected older friend gave me his top tip for efficiency: if you think of a job that needs doing and it will take you less than fifteen minutes, just do it – putting it on a list and then remembering it and then forgetting it again and repeatedly fretting about it will take much longer in the end. But it seems that we are suffering from a dearth of people who will simply knuckle down and do their job properly.
Recently I spotted an article in an Australian newspaper about the situation at NAB, currently being looked at by AUSTRAC (the Australian FIU). On 4 June 2021 AUSTRAC sent a letter to NAB warning them of “potential serious and ongoing non-compliance” with customer identification procedures, ongoing customer due diligence and compliance with AML/CFT requirements, and saying that these concerns have been referred to AUSTRAC’s enforcement team. According to the article in The Age, former workers at NAB say that the bank is “using contractors in fraud, sanctions and anti-money laundering roles”. Of course, there is nothing wrong with contractors per se – indeed, many businesses would not survive without them. But it is crucial – particularly in roles such as these, at the forefront of AML/CFT – that even the most casual of workers is given appropriate training. And according to the article, “many former casual NAB workers said they received little or no formal training when they joined the bank’s financial crime team”.
Unsurprisingly, I think that AML/CFT training is vital for all staff, at some level – after all, every single person can do something to protect their institution. But those who work in financial crime prevention in any capacity should receive detailed, specific training – and certainly not the ad hoc “sitting beside someone and listening into their calls” variety mentioned in the NAB situation. Here in the UK, the training obligation applies to “relevant employees”, and the definition of that (Regulation 24) makes no distinction between full-time or part-time, formal or casual, employee or consultant. For the firm, it’s a legal obligation. For the MLRO, it’s a case of having the right people capable of doing the right work. And for the member of staff, it would be madness to take on such responsibility without the training. So, once again, just do it.