Top tips for MLROs

And so here we are: my final weekly blog post.  I could think of no more fitting topic than my top five tips for MLROs, garnered over twenty-five years of working with you.

  1. Get people to care.  It’s all very well reminding staff about the legislation and penalties, about your policies and procedures, but we all know that no-one works to their highest standard unless they care about what they’re doing.  So tell them about people trafficking and drug overdoses and the sale of child pornography and the poaching of wild animals and the theft of state assets and how their tax bills are higher because so many people are evading their obligations.  And explain that money laundering is the crime that allows all other crimes to flourish – and that AML is our best weapon against it.
  2. Tell them stories.  Yes, I know your staff and directors are all grown-ups, but we all love a good story.  So research the latest money laundering convictions – particularly those that involve your sector and your type of clients (and you know there will be some) – and turn the bland details into an exciting tale of the triumph of AML (or at least, the triumph of money laundering investigation) over the forces of evil.
  3. Record everything.  We all agree that the risk-based approach is the most sensible, as it allows you to vary your AML according to the risk presented, but the price you pay for that is that someone in the future could question your decisions.  Did you assess the client correctly?  Did you put them into the right CDD category – and was that CDD applied without fear or favour?  To protect yourself, record it all: every client interaction, every search for corroboration, every deliberation, every decision.  Drum it into your staff that file notes are an essential part of it all – not just filling in the standard forms.
  4. Meet other MLROs.  You may be the only MLRO in your firm.  But even if you are lucky enough to have a compliance team around you, so that you can bounce ideas around and discuss tricky situations, you will only be seeing things from the perspective of your own firm and your own sector.  Join MLRO groups so that you can meet others and see the problems and solutions from a different angle.  They may well have already cracked the vexatious issue with which you have been wrestling.  Which leads me to my final tip…
  5. Be generous.  Give freely of your time and your expertise.  When I started out in AML – in the early days of the Industrial Revolution – I was quite guarded about “giving away” my information.  But then my natural blabbermouth emerged and I discovered – miraculously – that the more I shared, the more I was given in return.  I would email someone a relevant news story – and a month later they would send me a copy of an expensive industry report.  I would take a quick look at someone’s AML policy – and a year later they would commission me to rewrite their whole manual.  But don’t just do it for what you can get out of it: we’re an AML community, and it’s only by co-operating and sharing that we will succeed (and enjoy it while we do).

And one very last observation, if I may.  When people say to you (and they will) “but what’s the point of AML – as long as there’s money there will be crime and money laundering”, just remember this.  For everything in life you have only two options: do something or do nothing.  Doing nothing in the face of money laundering was never possible for me – nor, I assume, for you – and genuine effort is never wasted.  If you have made life awkward for even one criminal, if you have blocked even one penny of criminal proceeds from moving through the financial sector, you have done more than most people and that’s a triumph.  I salute you all.

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30 Responses to Top tips for MLROs

  1. David Winch says:

    I will be uncharacteristically brief – thank you!

  2. Kevin Whitmore says:

    Very best wishes to you, and thank you for all the smiles

  3. David Livermore says:

    Dear Susan
    Before you go galloping off into the soaking wet Cambridgeshire sunset, I just wanted to thank you for all that you have done for us, and for me. Your training sessions were a wonderful mix of very serious reminders of this vast problem that we deal with on a daily basis, and humour, without which I have always found learning difficult! There are very few educators in this area that can inspire and enthuse as you can and you will be sorely missed. Please keep writing your books, cycling, sipping good reds and occasionally think about us poor souls battling on, but only very occasionally. With all good wishes for a happy and healthy future, David.

  4. Nathalie Pike says:

    Thank you Susan for your informative and entertaining blogs which I have very much enjoyed reading.

    You have shone a beacon of light on the importance of MLROs and how we can enable businesses to assist us in the fight against money laundering. It is never going to be the sexiest job in the workplace and I work hard at keeping a sense of humour, so that the human element of what I do is not overshadowed by the quotation of laws and regulations (which seem to increase year on year!)

    I wish you all the best.

    Nathalie

    ​Nathalie Pike Head of Compliance, Guernsey Let’s talk… t. +44 (0) 1481 739488 I am based in Guernsey Watch our brand film at sannegroup.com

  5. Spence, Ian says:

    Susan

    Couldn’t agree more.

    Best wishes for the future

    Cheers

    Ian

    Ian Spence – Head of AML / CFT – AML/CFT Division
    Isle of Man Financial Services Authority
    PO Box 58 • Finch Hill House • Bucks Road • Douglas • Isle of Man • IM99 1DT • ian.spence@iomfsa.im Tel: 01624 689328
    LinkedIn • Twitter • Facebook • 🔒 Privacy Policy

  6. Richard Romeril says:

    On Wed, 29 Dec 2021 at 10:38, I hate money laundering wrote:

    Will miss your regular blogs

    Happy new year

    Richard Romeril

    > ihatemoneylaundering posted: ” And so here we are: my final weekly blog > post. I could think of no more fitting topic than my top five tips for > MLROs, garnered over twenty-five years of working with you. Get people to > care. It’s all very well reminding staff about the legisla” > I

  7. Kwansema Dumor says:

    I have never responded to your blog posts but always read them with relish over the years! They have been a rare mix of generous information, intellect, wit and humour. You have such a way with words… I am sure there are many like me who loved reading your posts but never posted a response. Thank you for all you have contributed to the AML community! You will be missed. Wishing you a healthy, peaceful and fulfilled future.
    Blessings! 💐
    K.

  8. Stuart Wallace says:

    Susan, as a weekly reader of your informed and witty articles, I would like to say thank you for all you have done for MLROs and the AML community, and I would like to wish you a very happy retirement.

  9. Peter Wilson says:

    Dear Susan
    Thank you for all the work you have done in raising AML as an issue that affects all of us, in one way or another. Your AML books have always been one of my favourite methods to let staff know what they are meant to know – in a very easy to understand format. Enjoy your retirement – your contribution to the good fight will be missed. Peter

  10. Trevor Casbolt says:

    Thanks for all the info and stories over the years. Very sorry that you have decided to retire, but I hope you enjoy it.

  11. Geert Vermeulen says:

    Hi Susan,

    Thank you for your last post. And all the ones before this one. I just want to say that I have enjoyed reading them over the course of several years and also learned quite a lot from you, as I am used to be more focused on anti-corruption than on AML. But well, the two go hand-in-hand so at a given moment I decided I had to learn something about AML as well. It is a shame to see you leave the profession, but I hope that you will find other challenging and rewarding endeavors. All the best in 2022 and for many, many more years to come! And many Jaffa cakes!

    Kind regards, Geert Vermeulen ________________________________________ ECMC: Ethics & Compliance Management & Consulting Geert Vermeulen

    R.H. Fledderusstraat 17 3071 MH Rotterdam The Netherlands T: +31 6 52884699 E: geert.vermeulen@ethicscompliancemc.com W: http://www.ethicscompliancemc.com

    Chamber of Commerce Rotterdam no 64842258

    This email message is intended only for the individual to whom, or entity to which, it is addressed. If you have received this communication in error, please contact the sender and delete this message

    >

    • Dear Geert, thank you so much for your kind words – international readership! Yes, I am afraid that corruption seems to be growing rather than shrinking, not least in my own jurisdiction. And yes, Jaffa Cakes will continue to feature… Best wishes from Susan

  12. Hi Susan, Like the commentators above I have much enjoyed your wit and wisdom and wish you a very busy retirement. Best wishes, Tristram

  13. Donna Caira says:

    Hi Susan I’ve very much enjoyed your blogs over the years and the firm your training. You have brought a unique perspective to the AML community and it will be much missed. Wishing you all the best for the next chapters. Donna

  14. Jane Menzies says:

    Thank you, Susan! I will miss your informative and entertaining blogs but all good things must come to an end. Thanks again and very best wishes, Jane

  15. Roy McCarthy says:

    Well done for everything Susan. I think your final paragraph firmly trumps my cynicism over the usefulness of the compliance ‘industry’.

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